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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
ransporting or traveling with minors, she had no knowledge or intent that they engage in sexual conduct with Epstein. 167 EFTA00100134 States v. Sliker, 751 F.2d 477, 487 (2d Cir. 1984). Here, the defendant's specific and unique approach to preparing minor girls to engage in sex acts with Epstein de
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
r. 58 (KBF), 2014 WL 2696569 (S.D.N.Y. June 10, 2014) 126 United States v. Shaw, 260 F. Supp. 2d 567 (E.D.N.Y. 2003) 165, 171 United States v. Sliker, 751 F.2d 477 (2d Cir. 1984) 255 United States v. Smith, 985 F. Supp. 2d 547 (S.D.N.Y. 2014) 241, 243, 247 United States v. Smith, No. 05 Cr.
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
Cr. 58 (KBF), 2014 WL 2696569 (S.D.N.Y. June 10, 2014) 126 United States v. Shaw, 260 F. Supp. 2d 567 (E.D.N.Y. 2003) 165, 171 United States v. Sliker, 751 F.2d 477 (2d Cir. 1984) 255 United States v. Smith, 985 F. Supp. 2d 547 (S.D.N.Y. 2014) 241, 243, 247 United States v. Smith, No. 05 Cr.
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. (
ransporting or traveling with minors, she had no knowledge or intent that they engage in sexual conduct with Epstein. 167 EFTA00077799 States v. Sliker, 751 F.2d 477, 487 (2d Cir. 1984). Here, the defendant's specific and unique approach to preparing minor girls to engage in sex acts with Epstein de
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
Cr. 58 (KBF), 2014 WL 2696569 (S.D.N.Y. June 10, 2014) 126 United States v. Shaw, 260 F. Supp. 2d 567 (E.D.N.Y. 2003) 165, 171 United States v. Sliker, 751 F.2d 477 (2d Cir. 1984) 255 United States v. Smith, 985 F. Supp. 2d 547 (S.D.N.Y. 2014) 241, 243, 247 United States v. Smith, No. 05 Cr.
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. (
ransporting or traveling with minors, she had no knowledge or intent that they engage in sexual conduct with Epstein. 167 EFTA00039614 States v. Sliker, 751 F.2d 477, 487 (2d Cir. 1984). Here, the defendant's specific and unique approach to preparing minor girls to engage in sex acts with Epstein de
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
WL 1994014 (S.D.N.Y. Aug. 17, 2005) 183 United States v. Shaw, 260 F. Supp. 2d 567 (E.D.N.Y. 2003) 112, 115 xx EFTA00095087 United States v. Sliker, 751 F.2d 477 (2d Cir. 1984) United States v. Smith, 985 F. Supp. 2d 547 (S.D.N.Y. 2014) United States v. Smith, No. 05 Cr. 922 (DLC), 2007 WL 9
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
s enough that the characteristics relied upon are sufficiently idiosyncratic to permit a fair inference of a pattern's existence." United States v. Sliker, 751 F.2d 477, 487 (2d Cir. 1984). Here, the defendant's specific and unique approach to preparing minor girls to engage in sex acts with Epstein de
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. (
ransporting or traveling with minors, she had no knowledge or intent that they engage in sexual conduct with Epstein. 167 EFTA00103192 States v. Sliker, 751 F.2d 477, 487 (2d Cir. 1984). Here, the defendant's specific and unique approach to preparing minor girls to engage in sex acts with Epstein de
Entities connected to both Colleen McMahon and Sliker

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
Southern District of New York
ORGANIZATION
Colorado
LOCATION
Carpenter
PERSONSweet
PERSON
Bradley Edwards
PERSON
New York
LOCATIONJeffrey Pagliuca
PERSON
George W. Bush
PERSON