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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
k rendering that opinion in even further conflict with the well-reasoned decisions of numerous other Circuits. In particular, the Fourth, Ninth, and Eleventh Circuits have each adopted a per se rule favoring enforcement of a grand jury subpoena even where a protective order exists. See In re Grand Jury Subpoena,
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
k rendering that opinion in even further conflict with the well-reasoned decisions of numerous other Circuits. In particular, the Fourth, Ninth, and Eleventh Circuits have each adopted a per se rule favoring enforcement of a grand jury subpoena even where a protective order exists. See In re Grand Jury Subpoena,
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
k rendering that opinion in even further conflict with the well-reasoned decisions of numerous other Circuits. In particular, the Fourth, Ninth, and Eleventh Circuits have each adopted a per se rule favoring enforcement of a grand jury subpoena even where a protective order exists. See In re Grand Jury Subpoena,
Entities connected to both the "Litigation" and Eleventh Circuits

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.
ORGANIZATIONthe Government's Investigation and Application
ORGANIZATIONJ. Gorenstein
PERSONBranzburg v. Hayes
PERSON
Boies Schiller
ORGANIZATION
Department of Justice
ORGANIZATIONRoach
PERSONMeserve, Mumper & Hughes
ORGANIZATIONMartindell
PERSONthe Protective Order
ORGANIZATION