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s in the possession of Boies Schiller & Flexner LLP (the "A in connection with the matter v. Ghislaine Maxwell, et at (a"), 15 Civ. 7433 (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A. Background As described in the Application, the Government has served a grand jury subpoena (the "Subp
had at least called the witness before the grand jury). The subject matter of the Litigation also demonstrates the extraordinary circumstances of the Government's Investigation and Application, insofar as the materials at issue here appear not to be of the sort that ordinarily would provide protection against Government investigation. See
in the possession of Boies Schiller & Flexner LLP (the "A in connection with the matter v. Ghislaine Maxwell, et al. ("M"), 15 Civ. 7433 (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A. Background As described in the Application, the Government has served a grand jury subpoena (the "Subp
had at least called the witness before the grand jury). The subject matter of the Litigation also demonstrates the extraordinary circumstances of the Government's Investigation and Application, insofar as the materials at issue here appear not to be of the sort that ordinarily would provide protection against Government investigation. See
covery materials in the possession of Boies Schiller & Flexner LLP the "A in connection with the matter v. Ghislaine Maxwell, et al. (a), (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A. Background As described in the Application, the Government has served a grand jury subpoena (the "Subp
had at least called the witness before the grand jury). The subject matter of the Litigation also demonstrates the extraordinary circumstances of the Government's Investigation and Application, insofar as the materials at issue here appear not to be of the sort that ordinarily would provide protection against Government investigation. See
Entities connected to both the "Litigation" and the Government's Investigation and Application

Jeffrey Epstein
PERSON
David Boies
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
Prince Andrew
PERSONSouthern District
LOCATIONChemical Bank
ORGANIZATION
Orange
LOCATIONthe Federal Criminal Code
ORGANIZATIONFourt
ORGANIZATIONTeL Corp.
ORGANIZATIONEleventh Circuits
ORGANIZATIONJ. Gorenstein
PERSONBranzburg v. Hayes
PERSON
Boies Schiller
ORGANIZATION
Department of Justice
ORGANIZATIONRoach
PERSONMeserve, Mumper & Hughes
ORGANIZATIONMartindell
PERSONthe Protective Order
ORGANIZATION