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and to destroy efforts to use her experience to help others suffering as sex trafficking victims." (Id. at 8). 2. February 2016 Meeting Attorney Peter Skinner of Boies Schiller contacted AUSA-1, who was at that time the Human Trafficking and Project Safe Childhood Coordinator of the USAO-SDNY, to request a
he defendant invites the Court to engage in a balancing test that weighs the prejudice to the defendant against the Government's reasons for delay. (Del Mot. 7 at 5,6 n.4). This Court should reject the defendant's invitation. The defendant cites United States v. Brand, 556 F.2d 1312, 1317 n.7 (5th Cir.
stroy Giuffre's efforts to use her experience to help others suffering as sex trafficking victims." (Id. at 8). 2. February 2016 Meeting Attorney Peter Skinner of Boies Schiller contacted AUSA-1, who was at that time the Human Trafficking and Project Safe Childhood Coordinator of the USAO-SDNY, to request a
ance with the subpoenas. (Def. Mot. 3, Ex. C). Following a request by Judge Sweet for briefing supporting the Government's initial application, see Del Mot. 3, Ex. D at 4, 20; Ex. G at 6, the Government submitted a pane and sealed letters in support of its applications to each court on or about February
stroy Giuffre's efforts to use her experience to help others suffering as sex trafficking victims." (Id. at 8). 2. February 2016 Meeting Attorney Peter Skinner of Boies Schiller contacted AUSA-1, who was at that time the Human Trafficking and Project Safe Childhood Coordinator of the USAO-SDNY, to request a
ance with the subpoenas. (Def. Mot. 3, Ex. C). Following a request by Judge Sweet for briefing supporting the Government's initial application, see Del Mot. 3, Ex. D at 4, 20; Ex. G at 6, the Government submitted a pane and sealed letters in support of its applications to each court on or about February
Entities connected to both Peter Skinner and Del Mot

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
David Boies
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATIONSkinner
PERSON
Prince Andrew
PERSONSweet
PERSON
United States
LOCATION
United States Department of Justice
ORGANIZATION
Southern District of New York
ORGANIZATION
Julie K. Brown
PERSON
Department of Justice
ORGANIZATIONJane Doe
PERSONMartin Weinberg
PERSON
Stan Pottinger
PERSON
Colorado
LOCATION
Scarlett Johansson
PERSONSchneider
PERSON
Minnesota
LOCATION