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DNY and Boies Schiller] prior to the issuance of the subpoena on the subject of your investigation." (Del Mot. 3, Ex. E at 2 (emphasis added)).34 In Chemical 34 Tellingly, Maxwell omits the italicized portion of this question from her motion, thereby stripping important context from the nature of Chief J
o old, at most the door is barely ajar."). Substantial prejudice is just that—substantial, actual, non-speculative prejudice. See United States v. Birney, 686 F.2d 102, 105-06 (2d Cir. 1982) (a defendant's "proof of prejudice must be definite and not speculative"); see also United States v. Henderson,
DNY and Boies Schiller] prior to the issuance of the subpoena on the subject of your investigation." (Del Mot. 3, Ex. E at 2 (emphasis added)).34 In Chemical 34 Tellingly, Maxwell omits the italicized portion of this question from her motion, thereby stripping important context from the nature of Chief J
o old, at most the door is barely ajar."). Substantial prejudice is just that—substantial, actual, non-speculative prejudice. See United States v. Birney, 686 F.2d 102, 105-06 (2d Cir. 1982) (a defendant's "proof of prejudice must be definite and not speculative"); see also United States v. Henderson,
NY and Boies Schiller] prior to the issuance of the subpoena on the subject of your investigation." (Def. Mot. 3, Ex. E at 2 (emphasis added)).34 In Chemical Tellingly, Maxwell omits the italicized portion of this question from her motion, thereby stripping important context from the nature of Chief Judg
ited States v. Biaggi, 909 F.2d 662 (2d Cir. 1990) 298, 300 United States v. Bin Laden, 91 F. Supp. 2d 600 (S.D.N.Y. 2000) 240 United States v. Birney, 686 F.2d 102 (2d Cir. 1982) 61, 65 United States v. Bbrell, 470 F.2d 113 (2d Cir. 1972) 183 EFTA00103009 United States v. Blakney, 941 F.2
Entities connected to both Chemical and Birney

Jeffrey Epstein
PERSON
George W. Bush
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSON
Michael Jackson
PERSONMaria Farmer
PERSON
Eric Schmidt
PERSON
Prince Andrew
PERSON
David Boies
PERSON
Bradley Edwards
PERSON
Adriana Ross
PERSON
Supreme Court
ORGANIZATION
Michigan
LOCATION
Scarlett Johansson
PERSONthe Southern District
LOCATION
Kaplan
PERSONEmmy Taylor
PERSONMartindell
PERSON
George Mitchell
PERSON