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epositions 4 C. The Settlement And Boles Schiller's Refusal To Comply With The Protective Order 6 D. The Government's False Statements To Judge McMahon 6 E. Judge Netburn Separately Rejects An Identical Gambit By The Government 10 ARGUMENT 11 A. Pursuant To Its Inherent Power, This Court Sho
to make reference to certain subjects relating to the Investigation." That "publicly available information," the government claimed, indicated that the Boies Schiller file might "contain information relevant to the ongoing Investigation" of Jeffrey Epstein. Ex. C, 14. Nowhere did the government acknowledge that B
epositions 4 C. The Settlement And Boies Schiller's Refusal To Comply With The Protective Order 6 D. The Government's False Statements To Judge McMahon 6 E. Judge Netburn Separately Rejects An Identical Gambit By The Government 10 ARGUMENT 11 A. Pursuant To Its Inherent Power, This Court Sho
Page: EFTA00011453 →n in April 2019. Ex. E. Judge McMahon held that conference for one reason: to learn "about contacts between the United States Attorney's Office and the Boies Schiller law firm prior to the issuance of the subpoena." Ex. E, p 2. The Assistant U.S. Attorney told Judge McMahon that the government's investigation beg
Page: EFTA00011463 →imum, this Court Should Order a Hearing at which Maxwell May Inquire into the Circumstances Surrounding the Government's Misrepresentation to Judge McMahon 26 Conclusion 27 Certificate of Service 29 EFTA00029101 --- PAGE BREAK --- Table of Authorities Cases Abdell v. City of New York, No. 05 C
Page: EFTA00029101 →y should have told Judge McMahon about the February 2016 meeting when she asked him "about contacts between the United States Attorney's Office and the Boies Schiller firm prior to the issuance of the subpoena on the subject of your investigation"—i.e., Epstein. AUSA did not tell Chief Judge McMahon about the 17
Page: EFTA00029122 →epositions 4 C. The Settlement And Boies Schiller's Refusal To Comply With The Protective Order 6 D. The Government's False Statements To Judge McMahon 6 E. Judge Netburn Separately Rejects An Identical Gambit By The Government 10 ARGUMENT 11 A. Pursuant To Its Inherent Power, This Court Sho
Page: EFTA00029817 →n in April 2019. Ex. E. Judge McMahon held that conference for one reason: to learn "about contacts between the United States Attorney's Office and the Boies Schiller law firm prior to the issuance of the subpoena." Ex. E, p 2. The Assistant U.S. Attorney told Judge McMahon that the government's investigation beg
Page: EFTA00029827 →Entities connected to both Colleen McMahon and the Boies Schiller

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSON
David Boies
PERSONSecond Circuit
ORGANIZATIONMartindell
PERSON
Stephen Hawking
PERSON
Michael Cohen
PERSONJane Doe
PERSONJeffrey Pagliuca
PERSONStephen Rex Brown
PERSON
Schiller
PERSONLaura Menninger
PERSON
Boies Schiller
ORGANIZATIONChemical Bank
ORGANIZATION
Valentine
PERSON
Boies Schiller Flexner LLP
ORGANIZATION
Martha Stewart
PERSONCohen & Gresser LLP
ORGANIZATIONDistrict Court for the Southern District of New York
ORGANIZATION