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1998) 16 United States v. Cortina, 630 F.3d 1207 (7th Cir. 1980) 16 United States v. Lambus, 897 F.3d 368 (2d Cir. 2018) 16 United States v. Paredes-Cordova, No. S I 03 CR. 987DAB, 2009 WL 1585776 (S.D.N.Y. June 8, 2009) 18 United States v. Rajaratnam, 719 F.3d 139 (2d Cir. 2013) 18 United S
Page: EFTA00011454 →Judge McMahon that the prosecutors had no idea what was in Boies Schiller's file. Indeed, he insisted, there had been no contact whatsoever between Boies Schiller and United States Attorney's Office before the government commenced its investigation. Nor, said the prosecutor, did Boies Schiller have any
Page: EFTA00011457 →arties and an opportunity to be heard." Ex. A Y 14 (emphasis added). In its ex pane application, the prosecutors professed that they had sought out Boies Schiller's file only because "publicly available information regarding the [ v. Maxwell] 6 EFTA00011462 --- PAGE BREAK --- Litigation, includi
Page: EFTA00011463 →r. 2008) 22 United States v. Lambus, 897 F.3d 368 (2d Cir. 2018) 23, 25 United States v. Ming He, 94 F.3d 782 (2d Or. 1996) 20 United States v. Paredes-Cordova, No. SI 03 CR. 987DAB, 2009 WL 1585776 (S.D.N.Y. June 8, 2009) 25 ii EFTA00028931 --- PAGE BREAK --- United States v. Payner, 447 U.S.
Page: EFTA00028931 →en AUSA appeared before Judge McMahon barely four months later, however, he told her none of this, unequivocally and falsely disavowing any role by Boies Schiller in fomenting the investigation and denying any contacts between Boies Schiller and his office before November 2018. Even though AUSA had
Page: EFTA00028939 →y prosecution after a second meeting with attorneys, which took place after at least one of Maxwell's depositions. As reported in the Daily News, "David [Boles] was particularly frustrated by the failure to pursue a perjury charge.s13 "We have her dead to rights," he said.14 This Court cannot accept without
Page: EFTA00028946 →1998) 16 United States v. Cortina, 630 F.3d 1207 (7th Cir. 1980) 16 United States v. Lambus, 897 F.3d 368 (2d Cir. 2018) 16 United States v. Paredes-Cordova, No. S I 03 CR. 987DAB, 2009 WL 1585776 (S.D.N.Y. June 8, 2009) 18 United States v. Rajaratnam, 719 F.3d 139 (2d Cir. 2013) 18 United S
Page: EFTA00029079 →Judge McMahon that the prosecutors had no idea what was in Boies Schiller's file. Indeed, he insisted, there had been no contact whatsoever between Boies Schiller and United States Attorney's Office before the government commenced its investigation. Nor, said the prosecutor, did Boies Schiller have a
Page: EFTA00029082 →, AUSA met with attorneys from Boies Schiller, who "urged to open an investigation of Epstein and Maxwell!' Then, 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."
Page: EFTA00029089 →en AUSA appeared before Judge McMahon barely four months later, however, he told her none of this, unequivocally and falsely disavowing any role by Boies Schiller in fomenting the investigation and denying any contacts between Boies Schiller and his office before November 2018. Even though AUSA had
Page: EFTA00029110 →y prosecution after a second meeting with attorneys, which took place after at least one of Maxwell's depositions. As reported in the Daily News, "David [Boles] was particularly frustrated by the failure to pursue a perjury charge.s13 "We have her dead to rights," he said.14 This Court cannot accept without
Page: EFTA00029117 →o Judge McMahon. "An evidentiary hearing is normally required to address motions to suppress where a factual issue is in dispute." United States v. Paredes-Cordova, No. SI 03 CR. 987DAB, 2009 WL 1585776, at *1 June 8, 2009); United States v. Pena, 961 F.2d 333, 339 (2d Cir. 1992) ("[All evidentiary he
Page: EFTA00029130 →1998) 16 United States v. Cortina, 630 F.3d 1207 (7th Cir. 1980) 16 United States v. Lambus, 897 F.3d 368 (2d Cir. 2018) 16 United States v. Paredes-Cordova, No. S I 03 CR. 987DAB, 2009 WL 1585776 (S.D.N.Y. June 8, 2009) 18 United States v. Rajaratnam, 719 F.3d 139 (2d Cir. 2013) 18 United S
Page: EFTA00029818 →Judge McMahon that the prosecutors had no idea what was in Boies Schiller's file. Indeed, he insisted, there had been no contact whatsoever between Boies Schiller and United States Attorney's Office before the government commenced its investigation. Nor, said the prosecutor, did Boies Schiller have a
Page: EFTA00029821 →met with attorneys from Boies Schiller, who "urged Kramer to open an investigation of" Epstein and Maxwell!' Then, 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."
Page: EFTA00029828 →Entities connected to both David Boies and Paredes

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONSigrid McCawley
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJane Doe
PERSONJeffrey Pagliuca
PERSON
Julie K. Brown
PERSON
Boies Schiller
ORGANIZATION
Department of Justice
ORGANIZATIONLaura Menninger
PERSON
Michael Cohen
PERSON
Harvey Weinstein
PERSON
Boies Schiller Flexner LLP
ORGANIZATIONSecond Circuit
ORGANIZATION
Martha Stewart
PERSON
Southern District of New York
ORGANIZATION
Stephen Hawking
PERSON
Supreme Court
ORGANIZATION
Paul Ryan
PERSON