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against him"; and the Government did not seek the deposition "to aid it in a criminal investigation or grand jury proceeding." Id. at 700; see also Botha v. Don King Productions, Inc., No. 97 Civ. 7587 (JGK), 1998 WL 88745 (S.D.N.Y. Feb. 27, 1998) (noting importance of policy concerns of Martindell wh
). 9. The New York Daily News Article On October 13, 2020, the New York Daily News published an article describing the February 29, 2016 meeting (the "Daily News Article" or the "Article").35 The Article stated, among other things, that defense attorneys representing victims of Epstein and Maxwell "urged" the USAO-S
against him"; and the Government did not seek the deposition "to aid it in a criminal investigation or grand jury proceeding." Id. at 700; see also Botha v. Don King Productions, Inc., No. 97 Civ. 7587 (JGK), 1998 WL 88745 (S.D.N.Y. Feb. 27, 1998) (noting importance of policy concerns of Martindell wh
). 9. The New York Daily News Article On October 13, 2020, the New York Daily News published an article describing the February 29, 2016 meeting (the "Daily News Article" or the "Article").35 The Article stated, among other things, that defense attorneys representing victims of Epstein and Maxwell "urged" the USAO-S
against him"; and the Government did not seek the deposition "to aid it in a criminal investigation or grand jury proceeding." Id. at 700; see also Botha v. Don King Productions, Inc., No. 97 Civ. 7587 (JGK), 1998 WL 88745 (S.D.N.Y. Feb. 27, 1998) (noting importance of policy concerns of Martindell wh
). 9. The New York Daily News Article On October 13, 2020, the New York Daily News published an article describing the February 29, 2016 meeting (the "Daily News Article" or the "Article").35 The Article stated, among other things, that defense attorneys representing victims of Epstein and Maxwell "urged" the USAO-S
against him"; and the Government did not seek the deposition "to aid it in a criminal investigation or grand jury proceeding." Id. at 700; see also Botha v. Don King Productions, Inc., No. 97 Civ. 7587 (JGK), 1998 WL 88745 (S.D.N.Y. Feb. 27, 1998) (noting importance of policy concerns of Martindell wh
). 9. The New York Daily News Article On October 13, 2020, the New York Daily News published an article describing the February 29, 2016 meeting (the "Daily News Article" or the "Article") .36 The Article stated, among other things, that defense attorneys representing victims of Epstein and the defendant "urged" the
against him"; and the Government did not seek the deposition "to aid it in a criminal investigation or grand jury proceeding." Id. at 700; see also Botha v. Don King Productions, Inc., No. 97 Civ. 7587 (JGK), 1998 WL 88745 (S.D.N.Y. Feb. 27, 1998) (noting importance of policy concerns of Martindell wh
). 9. The New York Daily News Article On October 13, 2020, the New York Daily News published an article describing the February 29, 2016 meeting (the "Daily News Article" or the "Article").35 The Article stated, among other things, that defense attorneys representing victims of Epstein and Maxwell "urged" the USAO-S
Entities connected to both Botha and the "Daily News Article

Ghislaine Maxwell
PERSON
United States
LOCATION
Scarlett Johansson
PERSON
Jeffrey Epstein
PERSONStokes
PERSONMartindell
PERSONColleen McMahon
PERSON
Southern District of New York
ORGANIZATIONSweet
PERSON
Julie K. Brown
PERSONFisher
PERSONMaria Farmer
PERSONSubpoena Duces
PERSONProductions, Inc.
ORGANIZATION
David Boies
PERSONthe Southern District
LOCATIONStatistical Tabulating Corp.
ORGANIZATIONWerner
PERSON
Medina
PERSON
Supreme Court
ORGANIZATION