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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
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.
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
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.
ranscript, no contact women_ the ant at nallavernment ongation. (Def. Mot. 3 at 1). Instead, ChiefJudgeltNahon's cAlgaismore specific: rearing Chemical figgrand desire to avoid "a Chemical Bank kind OREM5n," Chief Judge Mahon asked about cont between the two parties "prior to the issuance of the sub
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
s investigation and the issuance of the subpoena. Additionally, and in light of the Government's prior arguments to Chief Judge McMahon relating to Chemical Bank,40 the Government attempted to address the misconduct at issue in that case: namely the production of confidential documents without seeking m
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 Chemical and Sliker

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSON
George W. Bush
PERSON
Michael Jackson
PERSON
Eric Schmidt
PERSON
Southern District of New York
ORGANIZATIONMaria Farmer
PERSON
Supreme Court
ORGANIZATION
Bradley Edwards
PERSON
Adriana Ross
PERSON
David Boies
PERSONBenussi
PERSON
Prince Andrew
PERSON
Figueroa
PERSONthe Southern District
LOCATIONConcepcion
PERSON
Michigan
LOCATIONSalinas
PERSON