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ority. Maxwell must thus make a substantial preliminary showing on each of Franks' requirements to justify an evidentiary hearing. United States v. Salamelz, 152 F.3d 88, 113 (2d Cir. 1998). That is, she must first make a substantial preliminary showing that the Government 15 EFTA00040678 deliberatel
ides no guarantee that compelled testimony will not somehow find its way into the government's hands for use in a subsequent criminal prosecution." Andover Data Servs. v. Stat. Tabulating Corp., 876 F.2d 1080, 1083 (2d Cir. 1989). As the Second Circuit has explained, a civil protective order may (as here) be overt
ority. Maxwell must thus make a substantial preliminary showing on each of Franks' requirements to justify an evidentiary hearing. United States v. Salamelz, 152 F.3d 88, 113 (2d Cir. 1998). That is, she must first make a substantial preliminary showing that the Government 15 EFTA00106053 Case 1:20-c
ides no guarantee that compelled testimony will not somehow find its way into the government's hands for use in a subsequent criminal prosecution." Andover Data Servs. v. Stat. Tabulating Corp., 876 F.2d 1080, 1083 (2d Cir. 1989). As the Second Circuit has explained, a civil protective order may (as here) be overt
ority. Maxwell must thus make a substantial preliminary showing on each of Franks' requirements to justify an evidentiary hearing. United States v. Salamelz, 152 F.3d 88, 113 (2d Cir. 1998). That is, she must first make a substantial preliminary showing that the Government 15 EFTA00066524 deliberatel
ides no guarantee that compelled testimony will not somehow find its way into the government's hands for use in a subsequent criminal prosecution." Andover Data Servs. v. Stat. Tabulating Corp., 876 F.2d 1080, 1083 (2d Cir. 1989). As the Second Circuit has explained, a civil protective order may (as here) be overt
ority. Maxwell must thus make a substantial preliminary showing on each of Franks' requirements to justify an evidentiary hearing. United States v. Salamelz, 152 F.3d 88, 113 (2d Cir. 1998). That is, she must first make a substantial preliminary showing that the Government 15 EFTA00087265 deliberatel
ides no guarantee that compelled testimony will not somehow find its way into the government's hands for use in a subsequent criminal prosecution." Andover Data Servs. v. Stat. Tabulating Corp., 876 F.2d 1080, 1083 (2d Cir. 1989). As the Second Circuit has explained, a civil protective order may (as here) be overt
ority. Maxwell must thus make a substantial preliminary showing on each of Franks' requirements to justify an evidentiary hearing. United States v. Salamelz, 152 F.3d 88, 113 (2d Cir. 1998). That is, she must first make a substantial preliminary showing that the Government 15 EFTA00087244 deliberatel
ides no guarantee that compelled testimony will not somehow find its way into the government's hands for use in a subsequent criminal prosecution." Andover Data Servs. v. Stat. Tabulating Corp., 876 F.2d 1080, 1083 (2d Cir. 1989). As the Second Circuit has explained, a civil protective order may (as here) be overt
e district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.")); United States v. Salamelz, 152 F.3d 88, 120 (2d Cir. 1998). This Circuit "presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively
eposition Exhibit 12: Affidavit of Dr. Bernard R. Siskin iv EFTA00077610 TABLE OF AUTHORITIES Cases Albright v. Oliver, 510 U.S. 266 (1993) Andover Data Servs., a Div. of Players Computer, Inc. v. Statistical Tabulating Corp., Page(s) 152 876 F.2d 1080 (2d Cir. 1989) 106, 119, 149 Arizona v. Youngblood
e district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.")); United States v. Salamelz, 152 F.3d 88, 120 (2d Cir. 1998). This Circuit "presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively
eposition Exhibit 12: Affidavit of Dr. Bernard R. Siskin iv EFTA00039425 TABLE OF AUTHORITIES Cases Albright v. Oliver, 510 U.S. 266 (1993) Andover Data Servs., a Div. of Players Computer, Inc. v. Statistical Tabulating Corp., Page(s) 152 876 F.2d 1080 (2d Cir. 1989) 106, 119, 149 Arizona v. Youngblood
e district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.")); United States v. Salamelz, 152 F.3d 88, 120 (2d Cir. 1998). This Circuit "presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively
72288 (E.D.N.Y. July 15, 2019) 2020 WL 3483702 (S.D.N.Y. June 26, 2020) 2021 WL 78235 (January 11, 2021) Albright v. Oliver, 510 U.S. 266 (1993) Andover Data Servs., a Div. of Players Computer, Inc. v. Statistical Tabulating Corp., 876 F.2d 1080 (2d Cir. 1989) 76, Arizona v. Youngblood, 488 U.S. 51 (1988) 1
e district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.")); United States v. Salamelz, 152 F.3d 88, 120 (2d Cir. 1998). This Circuit "presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively
eposition Exhibit 12: Affidavit of Dr. Bernard R. Siskin iv EFTA00103003 TABLE OF AUTHORITIES Cases Albright v. Oliver, 510 U.S. 266 (1993) Andover Data Servs., a Div. of Players Computer; Inc. v. Statistical Tabulating Corp., Page(s) 152 876 F.2d 1080 (2d Cir. 1989) 106, 119, 149 Arizona v. Youngblood
Entities connected to both Salamelz and Andover Data Servs

Ghislaine Maxwell
PERSONthe Southern District
LOCATION
United States
LOCATION
Jeffrey Epstein
PERSONMartindell
PERSON
Julie K. Brown
PERSONColleen McMahon
PERSON
David Boies
PERSONthe Second Circuit's
ORGANIZATIONFisher
PERSONCanfield
PERSON
Eric Schmidt
PERSON
Supreme Court
ORGANIZATION
Carpenter
PERSONSalameh
PERSONSubpoena Duces
PERSON
Southern District of New York
ORGANIZATIONBotha
PERSONProductions, Inc.
ORGANIZATIONStatistical Tabulating Corp.
ORGANIZATION