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mited number of emails from the attorneys (see Exs. 6 & 7).30 AUSA-1 did not participate in a second meeting with those attorneys and has never met David Boies. (See Ex. 4 at 4). AUSA-1 recalls being aware of depositions as a general matter, but she does not recall having knowledge of who had been deposed
gain cites the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obta
n, 896 F.3d 155 (2d Cir. 2018) 236 United States v. Thompson, No. 13 Cr. 378 (MN), 2013 WL 6246489 (S.D.N.Y. Dec. 3, 2013) 274 United States v. Torres, 901 F.2d 205 (2d Cir. 1990) 266, 268, 271 United States v. Towne, 870 F.2d 880 (2d Cir. 1989) 251 United States v. Tracy, 12 F.3d 1186 (2d Ci
mited number of emails from the attorneys (see Exs. 6 & 7).30 AUSA-1 did not participate in a second meeting with those attorneys and has never met David Boies. (See Ex. 4 at 4). AUSA-1 recalls being aware of depositions as a general matter, but she does not recall having knowledge of who had been deposed
gain cites the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obta
n, 896 F.3d 155 (2d Cir. 2018) 236 United States v. Thompson, No. 13 Cr. 378 (MN), 2013 WL 6246489 (S.D.N.Y. Dec. 3, 2013) 274 United States v. Torres, 901 F.2d 205 (2d Cir. 1990) 266, 268, 271 United States v. Towne, 870 F.2d 880 (2d Cir. 1989) 251 United States v. Tracy, 12 F.3d 1186 (2d Ci
ited number of emails from the attorneys (see Exs. 6 & 7).3° AUSA- I did not participate in a second meeting with those attorneys and has never met David Boies. (See Ex. 4 at 4). AUSA- I recalls being aware of depositions as a general matter, but she does not recall having knowledge of who had been deposed
ges, based on a New York Daily News article, that Boies Schiller and the Government colluded 60 EFTA000
Cr. 378 (AJN), 2013 WL 6246489 (S.D.N.Y. Dec. 3, 2013) 182, 189, 192 United States v. Thompson, 896 F.3d 155 (2d Cir. 2018) 156 United States v. Torres, 901 F.2d 205 (2d Cir. 1990) 174, 176, 179 United States v. Towne, 870 F.2d 880 (2d Cir. 1989) 165 United States v. Tracy, 12 F.3d 1186 (2d Ci
rtindell standard. "circ --- it cited 11 times in its argument to both relevant courts. (See (Exs. 8 Instead, the Government issued a subpoena to Boies in connection with its investigation, and made an application to two judges to modify Rule 26(c) protective orders that precluded full compliance
ot. 3, Ex. D at 17). In support of her argument, Maxwell cites again to the Daily News Article, which reports that "after Maxwell's two depositions, David Boies himself apparently approached the government in the summer of 2016, asking `if the Southern District would consider charging Maxwell with perjury' (
ils of the charge against him if this is necessary to the preparation of his defense, and to avoid prejudicial surprise at trial." United States v. Torres, 901 F.2d 205, 234 (2d Cir. 1990), abrogated on other grounds by United States v. Marcus, 628 F.3d 36, 41 (2d Cir.2010) (emphasis added) (internal q
gain cites the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obta
mited number of emails from the attorneys (see Exs. 6 & 7).30 AUSA-1 did not participate in a second meeting with those attorneys and has never met David Boies. (See Ex. 4 at 4). AUSA-1 recalls being aware of depositions as a general matter, but she does not recall having knowledge of who had been deposed
n, 896 F.3d 155 (2d Cir. 2018) 236 United States v. Thompson, No. 13 Cr. 378 (MN), 2013 WL 6246489 (S.D.N.Y. Dec. 3, 2013) 274 United States v. Torres, 901 F.2d 205 (2d Cir. 1990) 266, 268, 271 United States v. Towne, 870 F.2d 880 (2d Cir. 1989) 251 United States v. Tracy, 12 F.3d 1186 (2d Ci
ations are not explicitly referenced in his plea deal. The Washington Post (07/21, Rizzo), Los Angeles Times (07/21, Battaglio), Daily Beast (07/21, Bolies), Rolling Stone (07/21, Rawnsley), New York Post (07/21, DeGregory), and Business Insider (07/21, Davis) also reported on the story. A 'Help Me' Si
ported on by CBS News (07/21, Montoya-Galvez), the Texas Tribune (07/21, Schneid), Forbes (07/21, Bohannon), the Dallas Morning News (07/21, Gilman, Torres), Axios (07/21, Medoza), The Hill (07/21, Bernal), a second The Hill (07/21, Suter) article, HuffPost (07/21, Nicholson), New York Post (07/22, Cra
Entities connected to both David Boies and Torres

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONSigrid McCawley
PERSON
Prince Andrew
PERSON
Bradley Edwards
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
United States
LOCATION
Virginia Giuffre
PERSON
Paul Cassell
PERSONthe Southern District
LOCATION
Department of Justice
ORGANIZATIONJane Doe
PERSONLeon Black
PERSON
George Mitchell
PERSON
Julie K. Brown
PERSONSouthern District
LOCATION
George W. Bush
PERSON
Marc Rich
PERSON
Bill Clinton
PERSON