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ers to the Court so that the information can be made available to Maxwell, if appropriate, at the conclusion of each witness's direct testimony. See United States v. Giampa, No. S 92-CR-437 (PKL), 1992 WL 296440, at *3 *4 (S.D.N.Y. Oct. 7, 1992); United States v. Ferguson, No. 3:06-CR-137 (CFD), 2007 WL 457730
atory evidence is insufficient to justify enforcement of a Rule 17(c) subpoena (or, as here, issuance of such a subpoena in the face of objections). See United States v. Rich, No. S 83-CR- 579 (SWK), 1984 WL 845, at *3 (S.D.N.Y. Sept. 7, 1984). Maxwell's reliance on cases involving the Government's obligations und
cedure. As detailed in the subpoena and Maxwell's moving papers, she seeks authorization to serve a subpoena to the law firm of Boies, Schiller and Flexner LLP. BSF has filed a letter in opposition to the subpoena request. Additionally, the Government submitted a letter requesting that it be given notice of
ers to the Court so that the information can be made available to Maxwell, if appropriate, at the conclusion of each witness's direct testimony. See United States v. Giampa, No. S 92-CR-437 (PKL), 1992 WL 296440, at *3 *4 (S.D.N.Y. Oct. 7, 1992); United States v. Ferguson, No. 3:06-CR-137 (CFD), 2007 WL 457730
atory evidence is insufficient to justify enforcement of a Rule 17(c) subpoena (or, as here, issuance of such a subpoena in the face of objections). See United States v. Rich, No. S 83-CR- 579 (SWK), 1984 WL 845, at *3 (S.D.N.Y. Sept. 7, 1984). Maxwell's reliance on cases involving the Government's obligations und
cedure. As detailed in the subpoena and Maxwell's moving papers, she seeks authorization to serve a subpoena to the law firm of Boies, Schiller and Flexner LLP. BSF has filed a letter in opposition to the subpoena request. Additionally, the Government submitted a letter requesting that it be given notice of
ine Maxwell et al.. 15 Civ. 7433 (RWS) (S.D.N.Y.), notwithstanding the Protective Order. The foregoing is true under penalty of perjury. Assistant United Sta es Attorney Tel. (212) Dated: New York, New York February 5, 2019 4 CONFIDENTIAL SDNY_GM_00000837 EFTA00040601 Exhibit A CONFIDENTIAL SON,
an, United States Attorney for the Southern District of New York. I make this Affirmation and Application, pursuant to the All Writs Act, Title 28, United States Code, Section 1651, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP, in connection with the mat
All Writs Act, Title 28, United States Code, Section 1651, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP, in connection with the matter of v. Ghislaine Maxwell, et al.. 15 Civ. 7433 (RWS) (S.D.N.Y.). As further discussed below, the materials are curre
ers to the Court so that the information can be made available to Maxwell, if appropriate, at the conclusion of each witness's direct testimony. See United States v. Giampa, No. S 92-CR-437 (PKL), 1992 WL 296440, at *3 *4 (S.D.N.Y. Oct. 7, 1992); United States v. Ferguson, No. 3:06-CR-137 (CFD), 2007 WL 457730
atory evidence is insufficient to justify enforcement of a Rule 17(c) subpoena (or, as here, issuance of such a subpoena in the face of objections). See United States v. Rich, No. S 83-CR- 579 (SWK), 1984 WL 845, at *3 (S.D.N.Y. Sept. 7, 1984). Maxwell's reliance on cases involving the Government's obligations und
cedure. As detailed in the subpoena and Maxwell's moving papers, she seeks authorization to serve a subpoena to the law firm of Boies, Schiller and Flexner LLP. BSF has filed a letter in opposition to the subpoena request. Additionally, the Government submitted a letter requesting that it be given notice of
an, United States Attorney for the Southern District of New York. I make this Affirmation and Application, pursuant to the All Writs Act, Title 28, United States Code, Section 1651, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP, in connection with the mat
All Writs Act, Title 28, United States Code, Section 1651, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP, in connection with the matter of Ghislaine Maxwell, et al.. 15 Civ. 7433 (RWS) (S.D.N.Y.). As further discussed below, the materials are currentl
an, United States Attorney for the Southern District of New York. I make this Affirmation and Application, pursuant to the All Writs Act, Title 28, United States Code, Section 1651, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP, in connection with the mat
All Writs Act, Title 28, United States Code, Section 1651, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP, in connection with the matter of Jane Doe 43 v. Epstein, et al., 17 Civ. 616 (JGK)(SN) (S.D.N.Y.). As further discussed below, the materials are c
an, United States Attorney for the Southern District of New York. I make this Affirmation and Application, pursuant to the All Writs Act, Title 28, United States Code, Section 1651, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP, in connection with the mat
All Writs Act, Title 28, United States Code, Section 1651, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP, in connection with the matter of Jane Doe 43 v. Epstein, et al., 17 Civ. 616 (JGK)(SN) (S.D.N.Y.). As further discussed below, the materials are c
Entities connected to both United States and Flexner LLP

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSONthe Southern District
LOCATIONJane Doe
PERSON
Marc Rich
PERSON
Virginia Giuffre
PERSON
the United States District Court
ORGANIZATION
Geoffrey S. Berman
PERSON
Sarah Ferguson
PERSON
David Boies
PERSON
Cynthia Nixon
PERSON
Barneys New York
ORGANIZATION
Brady
PERSONSigrid McCawley
PERSONBates
PERSON
Giglio
PERSON
ALISON J. NATHAN
ORGANIZATIONSkelos
PERSON
Boies Schiller
ORGANIZATION