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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
States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 271 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 266, 267, 274 United States v. Botti, No. 08 Cr. 230 (CSH), 2009 WL 3157582 (D. Conn. Sept. 25, 2009) 218 United States v. Brand, 467 F.3d 179 (2d Cir. 2006) 236 United States v. B
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. (
statement itself concerned an entirely different subject matter, provable through largely if not entirely different evidence. See United States v. Botti, No. 08 Cr. 230 (CSH), 2009 WL 3157582, at *1, *5 (D. Conn. Sept. 25, 2009) (severing a structuring conspiracy and false statements related to that
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
States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 271 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 266, 267, 274 United States v. Botti, No. 08 Cr. 230 (CSH), 2009 WL 3157582 (D. Conn. Sept. 25, 2009) 218 United States v. Brand, 467 F.3d 179 (2d Cir. 2006) 236 United States v. B
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. (
statement itself concerned an entirely different subject matter, provable through largely if not entirely different evidence. See United States v. Botti, No. 08 Cr. 230 (CSH), 2009 WL 3157582, at *1, *5 (D. Conn. Sept. 25, 2009) (severing a structuring conspiracy and false statements related to that
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
States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 179 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 174, 175, 182 United States v. Botti, No. 08 Cr. 230 (CSH), 2009 WL 3157582 (D. Conn. Sept. 25, 2009) 145 United States v. Brand, 04 Cr. 194 (PKL), 2005 WL 77055 (S.D.N.Y. Jan. 12, 2
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
statement itself concerned an entirely different subject matter, provable through largely if not entirely different evidence. See United States v. Botti, No. 08 Cr. 230 (CSH), 2009 WL 3157582, at *1, *5 (D. Conn. Sept. 25, 2009) (severing a structuring conspiracy and false statements related to that
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
States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 271 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 266, 267, 274 United States v. Botti, No. 08 Cr. 230 (CSH), 2009 WL 3157582 (D. Conn. Sept. 25, 2009) 218 United States v. Brand, 467 F.3d 179 (2d Cir. 2006) 236 United States v. B
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. (
statement itself concerned an entirely different subject matter, provable through largely if not entirely different evidence. See United States v. Botti, No. 08 Cr. 230 (CSH), 2009 WL 3157582, at *1, *5 (D. Conn. Sept. 25, 2009) (severing a structuring conspiracy and false statements related to that
Entities connected to both Colleen McMahon and Botti

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSON
United States
LOCATIONMartin Weinberg
PERSON
Department of Justice
ORGANIZATIONFBI
ORGANIZATIONthe Southern District
LOCATION
David Boies
PERSON
Prince Andrew
PERSONMartindell
PERSON
Supreme Court
ORGANIZATION
Carpenter
PERSONSweet
PERSON
Colorado
LOCATIONJane Doe
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSON
Southern District of New York
ORGANIZATION
Eric Schmidt
PERSON