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dum, or other written communication of information of any kind." The use of the terms "all" and "any" "do not evince specificity." United States v. Tagliaferro, No. 19-CR-472 (PAC), 2021 WL 980004, at *3 (S.D.N.Y. Mar. 16, 2021). Here, the requests do not identify specific lawyers or employees of BSF whose
that review of these materials, if they become relevant and admissible, will lead to a delay at trial, given their limited volume. United States v. Seabrook, No. I6-CR-467, 2017 WL 4838311, at *2 (S.D.N.Y. Oct. 23, 2017). For documents that may ripen into relevance if and when the BSF clients testify, M
dum, or other written communication of information of any kind." The use of the terms "all" and "any" "do not evince specificity." United States v. Tagliaferro, No. 19-CR-472 (PAC), 2021 WL 980004, at *3 (S.D.N.Y. Mar. 16, 2021). Here, the requests do not identify specific lawyers or employees of BSF whose
that review of these materials, if they become relevant and admissible, will lead to a delay at trial, given their limited volume. United States v. Seabrook, No. I6-CR-467, 2017 WL 4838311, at *2 (S.D.N.Y. Oct. 23, 2017). For documents that may ripen into relevance if and when the BSF clients testify, M
dum, or other written communication of information of any kind." The use of the terms "all" and "any" "do not evince specificity." United States v. Tagliaferro, No. 19-CR-472 (PAC), 2021 WL 980004, at *3 (S.D.N.Y. Mar. 16, 2021). Here, the requests do not identify specific lawyers or employees of BSF whose
that review of these materials, if they become relevant and admissible, will lead to a delay at trial, given their limited volume. United States v. Seabrook, No. I6-CR-467, 2017 WL 4838311, at *2 (S.D.N.Y. Oct. 23, 2017). For documents that may ripen into relevance if and when the BSF clients testify, M
dum, or other written communication of information of any kind." The use of the terms "all" and "any" "do not evince specificity." United States v. Tagliaferro, No. 19-CR-472 (PAC), 2021 WL 980004, at *3 (S.D.N.Y. Mar. 16, 2021). Here, the requests do not identify specific lawyers or employees of BSF whose
Page: EFTA00020300 →that review of these materials, if they become relevant and admissible, will lead to a delay at trial, given their limited volume. United States v. Seabrook, No. I6-CR-467, 2017 WL 4838311, at *2 (S.D.N.Y. Oct. 23, 2017). For documents that may ripen into relevance if and when the BSF clients testify, M
Page: EFTA00020302 →Entities connected to both Tagliaferro and NORMAN SEABROOK

Cynthia Nixon
PERSON
Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Giglio
PERSON
Barneys New York
ORGANIZATION
United States
LOCATIONSkelos
PERSON
David Boies
PERSON
Brady
PERSON
Audrey Strauss
PERSONBergstein
PERSON
Marc Rich
PERSON
Sarah Ferguson
PERSONGiampa
PERSONSecond Circuit
ORGANIZATION
Michael Avenatti
PERSONFlexner LLP
ORGANIZATION
Aguilar
PERSON
Prince Andrew
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Chris Tucker
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