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n of copies of discovery and related materials related to the Litigation. The Subpoena was validly issued pursuant to an ongoing investigation into Jeffrey Epstein and others, for possible violations of Title 18, United States Code, Sections 1591 and 1594(c) (unlawfully trafficking minors) and Section 2422(b)
ce and scope of the Investigation in this district is not publicly known. While counsel for certain victims are aware of the Investigation, neither Epstein nor other subjects of the investigation are believed to be similarly aware. Accordingly, the ordinary exercise of grand July power to "subpoena witn
issued pursuant to an ongoing investigation into Jeffrey Epstein and others, for possible violations of T
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
r to unseal discovery materials in the possession of Boies Schiller & Flexner LLP (the "Application"), in connection with the matter Jane Doe 43 v. Epstein, et al. ("Jane Doe"), 17 Civ. 616 (JGK) (SN) (the "Litigation"), a copy of which is attached hereto as Exhibit A. Background As described in the A
n of copies of discovery and related materials related to the Litigation. The Subpoena was validly issued pursuant to an ongoing investigation into Jeffrey Epstein and others, for possible violations of Title 18, United States Code, Sections 1591 and 1594(c) (unlawfully trafficking minors) and Section 2422(b)
issued pursuant to an ongoing investigation into Jeffrey Epstein and others, for possible violations of T
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
n of copies of discovery and related materials related to the Litigation. The Subpoena was validly issued pursuant to an ongoing investigation into Jeffrey Epstein and others, for possible violations of Title 18, United States Code, Sections 1591 and 1594(c) (unlawfully trafficking minors) and Section 2422(b)
ce and scope of the Investigation in this district is not publicly known. While counsel for certain victims are aware of the Investigation, neither Epstein nor other subjects of the investigation are believed to be similarly aware. Accordingly, the ordinary exercise of grand July power to "subpoena witn
issued pursuant to an ongoing investigation into Jeffrey Epstein and others, for possible violations of T
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
n of copies of discovery and related materials related to the Litigation. The Subpoena was validly issued pursuant to an ongoing investigation into Jeffrey Epstein and others, for possible violations of Title 18, United States Code, Sections 1591 and 1594(c) (unlawfully trafficking minors) and Section 2422(b)
ce and scope of the Investigation in this district is not publicly known. While counsel for certain victims are aware of the Investigation, neither Epstein nor other subjects of the investigation are believed to be similarly aware. Accordingly, the ordinary exercise of grand jury power to "subpoena witn
issued pursuant to an ongoing investigation into Jeffrey Epstein and others, for possible violations of T
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 Jeffrey Epstein and the Government's Investigation and Application

Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Woody Allen
PERSON
George W. Bush
PERSONSouthern District
LOCATION
Department of Justice
ORGANIZATION
David Boies
PERSONSweet
PERSON
Boies Schiller
ORGANIZATION
Orange
LOCATIONRoach
PERSONMartindell
PERSONthe Protective Order
ORGANIZATIONS. BERMAN
PERSONChemical Bank
ORGANIZATIONSubpoena Duces
PERSON
Boies Schiller & Flexner LLP
ORGANIZATIONBranzburg v. Hayes
PERSON
Robert W. Sweet
PERSONthe "Litigation"
ORGANIZATION