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es, and thirty-some depositions, including depositions of and Maxwell as well as several third parties. See Brown v. Maxwell, 929 F.3d 41, 46, 51 (2d Cir. 2019) (explaining that discovery was "hard-fought" and "extensive" and noting that the court file, which includes only some of the documents created
Page: EFTA00011459 →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 →rs, and courts strictly enforce them. See, e.g., Stewart v. Hudson Hall LLC, 20 Civ. 885 (SLC), 2020 WL 7239676, at *2 (S.D.N.Y. Dec. 9, 2020) ("In the Second Circuit, there is a strict standard for modification of a protective order entered by a district court." (citation and quotation marks omitted)). This case
Page: EFTA00011467 →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 →that 'implies the duty of establishing and maintaining civilized standards of procedure and evidence.'" United States v. Ming He, 94 F.3d 782, 789 (2d Cir. 1996) (quoting McNabb, 318 U.S. at 340). As the Supreme Court held in United States v. Payner, "Federal courts may use their supervisory power in s
Page: EFTA00029124 →Cir. 2019) (citing Fed. R. Civ. P. 5.2). So, too, has Judge Preska redacted substantial material from the documents she has released on remand from the Second Circuit, again reflecting that Maxwell reasonably relied on the Protective Order. 20 EFTA00029124 --- PAGE BREAK --- reports were replete with misrepre
Page: EFTA00029125 →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 →rders in civil litigation. Protective orders serve a "vital function" in civil litigation. Martindell v. Intl Tel. & Tel. Corp., 594 F.2d 291, 295 (2d Cir. 1979). They promote "the `secure the just, speedy, and inexpensive determination' of civil disputes, by encouraging full disclosure of all evidence.
Page: EFTA00029831 →rs, and courts strictly enforce them. See, e.g., Stewart v. Hudson Hall LLC, 20 Civ. 885 (SLC), 2020 WL 7239676, at *2 (S.D.N.Y. Dec. 9, 2020) ("In the Second Circuit, there is a strict standard for modification of a protective order entered by a district court." (citation and quotation marks omitted)). This case
Page: EFTA00029831 →Entities connected to both Second Circuit and the Boies Schiller

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSONJane Doe
PERSON
Michael Cohen
PERSONJeffrey Pagliuca
PERSON
David Boies
PERSON
Stephen Hawking
PERSONDistrict Court for the Southern District of New York
ORGANIZATIONLaura Menninger
PERSONCohen & Gresser LLP
ORGANIZATIONBobbi C. Sternheim
PERSONU.S. Attorney's Office
ORGANIZATIONMartindell
PERSONMark S. Cohen
PERSONColleen McMahon
PERSON
Martha Stewart
PERSON
Giglio
PERSON
Boies Schiller
ORGANIZATION
Christian R. Everdell
PERSON