Epstein Secrets

r 18, 2018. Shortly thereafter, in or about December or January 2018, the Government indicated to at I that it intended to make document requests. Schiller generally advised the Government that a protective order would govern some of the materials. (Id. at 3). In or about February 2019, approximately t

tates v. Oshatz, 700 F. Supp. 696 (S.D.N.Y. 1988) 147, 148 United States v. Page, 657 F.3d 126 (2d Cir. 2011) 205,209,210,220 United States v. Pascarella, 84 F.3d 61 (2d Cir. 1996) 252 United States v. Paulino, 445 F.3d 211 (2d Cir. 2006) 253 United States v. Payner, 447 U.S. 727 (1980) 115, 16

ast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. Aside from

the defendant's bad character, or unless it is overly prejudicial under Fed. R. Evid. 403 or not relevant under Fed. R. Evid. 402." United States v. Pascarella, 84 F.3d 61, 69 (2d Cir. 1996) (internal citation omitted); see also United States v. Paulino, 445 F.3d 211, 221 (2d Cir. 2006); United States v. Z

ast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. Aside from

the defendant's bad character, or unless it is overly prejudicial under Fed. R. Evid. 403 or not relevant under Fed. R. Evid. 402." United States v. Pascarella, 84 F.3d 61, 69 (2d Cir. 1996) (internal citation omitted); see also United States v. Paulino, 445 F.3d 211, 221 (2d Cir. 2006); United States v. Z

bpoenas and Ex Pane Applications for Materials SOW- after opening t mment identified possible victims and their counsel trroiigh ich ina Boies Schiller. (Def. Mem. 3, Ex. E at 2-3). SDNY first cont oies Schiller about its investigation on or about December 18, 2018. Shortly thereafter, in oar Dec

tz, 700 F. Supp. 696 (S.D.N.Y. 1988) 102 xvii EFTA00095084 United States v. Page, 657 F.3d 126 (2d Cir. 2011) 138, 140, 147 United States v. Pascarella, 84 F.3d 61 (2d Cir. 1996) 165 United States v. Paulin, 445 F.3d 211 (2d Cir. 2006) 165 United States v. Payner, 447 U.S. 727 (1980) 82, 110

t complying with any of the specific procedures or exceptions provided in the [confidentiality] orders." Id. Here, by contrast, ga on in late 0111 Schiller shortly the na in Februan Miran order, Aside from rank speculation loosely premised on an anonymously sourced news report, the defendant offers n

the defendant's bad character, or unless it is overly prejudicial under Fed. R. Evid. 403 or not relevant under Fed. R. Evid. 402." United States v. Pascarella, 84 F.3d 61, 69 (2d Cir. 1996) (internal citation omitted); see also United States v. Paulin, 445 F.3d 211, 221 (2d Cir. 2006); United States v. Za

ast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. Aside from

the defendant's bad character, or unless it is overly prejudicial under Fed. R. Evid. 403 or not relevant under Fed. R. Evid. 402." United States v. Pascarella, 84 F.3d 61, 69 (2d Cir. 1996) (internal citation omitted); see also United States v. Paulin, 445 F.3d 211, 221 (2d Cir. 2006); United States v. Za