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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
s v. Calandra, 414 U.S. 338, 343 (1974)). "Wide latitude in gathering evidence is vital to the grand jury's investigative function." Id. at 422; see Branzburg v. Hayes, 408 U.S. 665, 688 (1972) ("Although the powers of the grand jury are not unlimited and are subject to the 78 EFTA00077710 supervision
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
s v. Calandra, 414 U.S. 338, 343 (1974)). "Wide latitude in gathering evidence is vital to the grand jury's investigative function." Id. at 422; see Branzburg v. Hayes, 408 U.S. 665, 688 (1972) ("Although the powers of the grand jury are not unlimited and are subject to the 78 EFTA00039525 supervision
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
ons, Inc., No. 97 Civ. 7587 (JGK), 1998 WL 88745 (S.D.N.Y. Feb. 27, 1998) 102 Boyd v. United States, 116 U.S. 616 (1886) 101 iv EFTA00095071 Branzburg v. Hayes, 408 U.S. 665 (1972) 78 Bridges v. United States, 346 U.S. 209 (1953) 38 Bronston v. United States, 409 U.S. 352 (1973) 121 Bryson
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
s v. Calandra, 414 U.S. 338, 343 (1974)). "Wide latitude in gathering evidence is vital to the grand jury's investigative function." Id. at 422; see Branzburg v. Hayes, 408 U.S. 665, 688 (1972) ("Although the powers of the grand jury are not unlimited and are subject to the supervision of a judge, the lon
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
s v. Calandra, 414 U.S. 338, 343 (1974)). "Wide latitude in gathering evidence is vital to the grand jury's investigative function." Id. at 422; see Branzburg v. Hayes, 408 U.S. 665, 688 (1972) ("Although the powers of the grand jury are not unlimited and are subject to the 78 EFTA00103103 supervision
t. 28, 1997) 15 iv EFTA00728012 Salvatorie Studios. Int'l v. Mako's. Inc., No. 01 Civ. 4430BSIDF. 2001 WL 913945 (S.D.N.Y. Aug. 14, 1991) 11 Schiller v. City of New York 2 245 F.R.D. 112 (S.D.N.Y. 2007) Solarex Corp. v. Arco Solar. Inc., 4 121 F.R.D. 163 (E.D.N.Y. 1988) Ulrich v. Coast Dental
to non-party subpoenas in private civil disputes. Lee v. Department of Justice. 413 F.3d 53, 58 (D.C. Cir. 2005) (limiting "the applicability of the Branzburg precedent to the circumstances considered by the court in Branzburg-that is. the context of a criminal proceeding, or even more specifically, a gra
t. 28, 1997) 15 iv EFTA00207335 Salvatorie Studios. Int'l v. Mako's. Inc., No. 01 Civ. 4430BSIDF. 2001 WL 913945 (S.D.N.Y. Aug. 14, 1991) 11 Schiller v. City of New York 2 245 F.R.D. 112 (S.D.N.Y. 2007) Solarex Corp. v. Arco Solar. Inc., 4 121 F.R.D. 163 (E.D.N.Y. 1988) Ulrich v. Coast Dental
to non-party subpoenas in private civil disputes. Lee v. Department of Justice. 413 F.3d 53, 58 (D.C. Cir. 2005) (limiting "the applicability of the Branzburg precedent to the circumstances considered by the court in Branzburg-that is. the context of a criminal proceeding, or even more specifically, a gra
such investigations it may compel the production of documentary evidence or the testimony of witnesses, as it deems necessary." Id. at 421-22; see Branzburg v. Hayes, 408 U.S. 665, 688 (1972) ("Although the powers of the grand jury are not unlimited and are subject to the supervision of a judge, the lon
Page: EFTA00011523 →tance, unlike in Subpoena Duces Tecum, the posture of the Application does not involve a motion to quash. Of course, should this Court permit Boies Schiller to respond, Boies Schiller would have the right to move to quash—including, for example, if a grand jury subpoena made any improper requests, such a
Page: EFTA00011524 →Entities connected to both Schiller and Branzburg v. Hayes

Jeffrey Epstein
PERSON
David Boies
PERSON
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSON
Bradley Edwards
PERSONJane Doe
PERSONLoretta A. Preska
PERSONMartindell
PERSON
Stephen Hawking
PERSONSecond Circuit
ORGANIZATION
Prince Andrew
PERSON
United States
LOCATION
George W. Bush
PERSON
Southern District of New York
ORGANIZATIONColleen McMahon
PERSONthe Southern District
LOCATIONSweet
PERSON
Boies Schiller
ORGANIZATIONJeffrey Pagliuca
PERSON
Virginia Giuffre
PERSON