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r. 2006) ("A claim of multiplicity cannot succeed, however, `unless the charged offenses am the same in fact and in law."' (quoting United States v. Estrada, 320 F.3d 173, 180 (2d Cir. 2003)). Although the Double Jeopardy Clause does not protect against simultaneous prosecutions for the same offense, a
e this is fine for you to disclose this in formation to the government based on the validly issued grand jury subpoena"); cf. (id. at 4 (Chief Judge McMahon describing Chemical Bank as saying "the proper procedure [for the production of documents] is for somebody to make a motion to be relieved from the
ited States v. El-Sadig, 133 F. Supp. 2d 600 (N.D. Ohio 2001) 23 United States v. Elsbery, 602 F.2d 1054 (2d Cir. 1979) 62, 72 United States v. Estrada, 320 F.3d 173 (2d Cir. 2003) 259 United States v. Ewell, 383 U.S. 116 (1966) 80 EFTA00099954 United States v. Falso, 544 F.3d 110 (2d Cir. 2
der is unreasonable where, as here, the protective order is on its face temporary or limited." (Id. at 3-4). 6. Proceedings before a. Chief Judge McMahon Mich 26,2019 Hearing Judge Sweet passed away in March 2019 before ruling on the Government's application. After Judge Sweet's death, but before the
ited States v. E!-Sadig, 133 F. Supp. 2d 600 (N.D. Ohio 2001) 23 United States v. Elsbery, 602 F.2d 1054 (2d Cir. 1979) 62, 72 United States v. Estrada, 320 F.3d 173 (2d Cir. 2003) 259 United States v. Ewell, 383 U.S. 116 (1966) 80 EFTA00077619 United States v. Falso, 544 F.3d 110 (2d Cir. 2
ces the Instant Investigation in 2018 65 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials 66 6. Proceedings before Chief Judge McMahon 68 a. March 26, 2019 Hearing 68 b. April 9, 2019 Hearing 70 EFTA00077607 c. Chief Judge McMahon's Memorandum and Order 71 7. Magistrate Judge
. 2006) ("A claim of multiplicity cannot succeed, however, 'unless the charged offenses are the same in fact and in law."' (quoting United States v. Estrada, 320 F.3d 173, 180 (2d Cir. 2003)). Although the Double Jeopardy Clause does not protect against simultaneous prosecutions for the same offense, a
Judge Netbum, who had not yet ruled on the Government's other application in Jane Doe 43 v. Epstein, et at, 17 Civ. 0616 (JGK) (SN), of Chief Judge McMahon's decision via a pane and sealed letter. (Def. Mot. 3, Ex. I). Subsequently, on April 16, 2019, Judge Netburn denied the Government's application. (
ited States v. E!-Sadig, 133 F. Supp. 2d 600 (N.D. Ohio 2001) 23 United States v. Elsbery, 602 F.2d 1054 (2d Cir. 1979) 62, 72 United States v. Estrada, 320 F.3d 173 (2d Cir. 2003) 259 United States v. Ewell, 383 U.S. 116 (1966) 80 EFTA00039434 United States v. Falso, 544 F.3d 110 (2d Cir. 2
ces the Instant Investigation in 2018 65 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials 66 6. Proceedings before Chief Judge McMahon 68 a. March 26, 2019 Hearing 68 b. April 9, 2019 Hearing 70 EFTA00039422 c. Chief Judge McMahon's Memorandum and Order 71 7. Magistrate Judge
. 2006) ("A claim of multiplicity cannot succeed, however, 'unless the charged offenses are the same in fact and in law."' (quoting United States v. Estrada, 320 F.3d 173, 180 (2d Cir. 2003)). Although the Double Jeopardy Clause does not protect against simultaneous prosecutions for the same offense, a
Judge Netbum, who had not yet ruled on the Government's other application in Jane Doe 43 v. Epstein, et at, 17 Civ. 0616 (JGK) (SN), of Chief Judge McMahon's decision via a pane and sealed letter. (Def. Mot. 3, Ex. I). Subsequently, on April 16, 2019, Judge Netburn denied the Government's application. (
ited States v. E!-Sadig, 133 F. Supp. 2d 600 (N.D. Ohio 2001) 19 United States v. Elsbery, 602 F.2d 1054 (2d Cir. 1979) 43, 49 United States v. Estrada, 320 F.3d 173 (2d Cir. 2003) 169 United States v. Ewell, 383 U.S. 116 (1966) 54 xii EFTA00095079 United States v. Falso, 544 F.3d 110 (2d C
eedin s before 5. The USAO-SDNY's Sub.. nas and Ex Pane Applications for Materials 66 a. M 68 b. April ', 70 EFTA00095068 c. Chief Judge McMahon's Memorandum and Order 71 7. &OAS% 74 8. Unsealing of Maxwell's Depositions 74 9. The New York Daily News Article 75 B. The Defendant's Sup
. 2006) ("A claim of multiplicity cannot succeed, however, `unless the charged offenses are the same in fact and in law."' (quoting United States v. Estrada, 320 F.3d 173, 180 (2d Cir. 2003)). Although the Double Jeopardy Clause does not protect against simultaneous prosecutions for the same offense, a
eir' ginndell in the altemalEMENty, both Challudge firTihron and rt ige that Martindell applied allialliEleappan under that framewial As chAllige McMahon found, even under the Martindell approach, testimony provided pursuant to a protective order can be divulged to a grand jury if the government estab
ited States v. El-Sadig, 133 F. Supp. 2d 600 (N.D. Ohio 2001) 23 United States v. Elsbery, 602 F.2d 1054 (2d Cir. 1979) 62, 72 United States v. Estrada, 320 F.3d 173 (2d Cir. 2003) 259 United States v. Ewell, 383 U.S. 116 (1966) 80 EFTA00103012 United States v. Falso, 544 F.3d 110 (2d Cir. 2
ces the Instant Investigation in 2018 65 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials 66 6. Proceedings before Chief Judge McMahon 68 a. March 26, 2019 Hearing 68 b. April 9, 2019 Hearing 70 EFTA00103000 c. Chief Judge McMahon's Memorandum and Order 71 7. Magistrate Judge
. 2006) ("A claim of multiplicity cannot succeed, however, `unless the charged offenses are the same in fact and in law."' (quoting United States v. Estrada, 320 F.3d 173, 180 (2d Cir. 2003)). Although the Double Jeopardy Clause does not protect against simultaneous prosecutions for the same offense, a
Judge Netbum, who had not yet ruled on the Government's other application in Jane Doe 43 v. Epstein, et at, 17 Civ. 0616 (JGK) (SN), of Chief Judge McMahon's decision via a pane and sealed letter. (Def. Mot. 3, Ex. I). Subsequently, on April 16, 2019, Judge Netburn denied the Government's application. (
Entities connected to both Estrada and Colleen McMahon

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSON
United States
LOCATION
Department of Justice
ORGANIZATIONMartin Weinberg
PERSONFBI
ORGANIZATIONthe Southern District
LOCATION
David Boies
PERSON
Prince Andrew
PERSONMartindell
PERSON
Bradley Edwards
PERSON
Supreme Court
ORGANIZATION
Colorado
LOCATION
Southern District of New York
ORGANIZATION
New York
LOCATION
Carpenter
PERSONJane Doe
PERSONSweet
PERSON
Michael Jackson
PERSON