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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
Contrary to the defendant's claims (Def. Mot. 11 at 10), she assumed the risk that the would divulged to the Government. See, e.g.,United States v. Schaefer, No. 17 Cr. 400 (HZ), 2019 WL 267711, at *5 (D. Or. Jan. 17, 2019) (declining to apply Carpenter where government obtained defendant's eBay transac
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
67,68,71 United States v. Scarpa, 897 F.2d 63 (2d Cir. 1990) 69 United States v. Scarpa, 913 F.2d 993 (2d Cir. 1990) passim United States v. Schaefer, No. 17 Cr. 400 (HZ), 2019 WL 267711 (D. Or. Jan. 17, 2019) 121 xxi EFTA00099962 United States v. Schalk-id-, 871 F.2d 300 (2d Cir. 1989) 1
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
67, 68, 71 United States v. Scaipa, 897 F.2d 63 (2d Cir. 1990) 69 United States v. Scaipa, 913 F.2d 993 (2d Cir. 1990) passim United States v. Schaefer, No. 17 Cr. 400 (HZ), 2019 WL 267711 (D. Or. Jan. 17. 2019) 121 xxi EFTA00077627 United States v. Schafrick, 871 F.2d 300 (2d Cir. 1989) 182
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. (
nt's claims (Def. Mot. 11 at 10), she assumed the risk that the deposition transcripts would divulged to the Government. See, e.g., United States v. Schaefer, No. 17 Cr. 400 (HZ), 2019 WL 267711, at *5 (D. Or. Jan. 17, 2019) (declining to apply Carpenter where government obtained defendant's eBay transac
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
67, 68, 71 United States v. Scaipa, 897 F.2d 63 (2d Cir. 1990) 69 United States v. Scaipa, 913 F.2d 993 (2d Cir. 1990) passim United States v. Schaefer, No. 17 Cr. 400 (HZ), 2019 WL 267711 (D. Or. Jan. 17. 2019) 121 xxi EFTA00039442 United States v. Schafrick, 871 F.2d 300 (2d Cir. 1989) 182
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. (
nt's claims (Def. Mot. 11 at 10), she assumed the risk that the deposition transcripts would divulged to the Government. See, e.g., United States v. Schaefer, No. 17 Cr. 400 (HZ), 2019 WL 267711, at *5 (D. Or. Jan. 17, 2019) (declining to apply Carpenter where government obtained defendant's eBay transac
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
nited States v. Scaipa, 913 F.2d 993 (2d Cir. 1990) 159, 160, 162, 164 United States v. Scaipa, 913 F.3d 993 (2d Cir. 1990) 42 United States v. Schaefer, No. 17 Cr. 400 (HZ), 2019 WL 267711 (D. Or. Jan. 17, 2019) 86 United States v. Schafrick, 871 F.2d 300 (2d Cir. 1989) 121 United States v. Sch
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
Contrary to the defendant's claims (Def. Mot. 11 at 10), she assumed the risk that the would divulged to the Government. See, e.g., United States v. Schaefer, No. 17 Cr. 400 (HZ), 2019 WL 267711, at *5 (D. Or. Jan. 17, 2019) (declining to apply Carpenter where government obtained defendant's eBay transac
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
, 68, 71 United States v. Scam pa, 897 F.2d 63 (2d Cir. 1990) 69 United States v. Scam pa, 913 F.2d 993 (2d Cir. 1990) passim United States v. Schaefer, No. 17 Cr. 400 (HZ), 2019 WL 267711 (D. Or. Jan. 17, 2019) 121 xxi EFTA00103020 United States v. Schafrick, 871 F.2d 300 (2d Cir. 1989) 18
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. (
nt's claims (Def. Mot. 11 at 10), she assumed the risk that the deposition transcripts would divulged to the Government. See, e.g., United States v. Schaefer, No. 17 Cr. 400 (HZ), 2019 WL 267711, at *5 (D. Or. Jan. 17, 2019) (declining to apply Carpenter where government obtained defendant's eBay transac
Entities connected to both Colleen McMahon and Schaefer

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