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ns To Judge McMahon 16 CONCLUSION 16 Certificate of Service 18 EFTA00011453 --- PAGE BREAK --- TABLE OF AUTHORITIES Cases Benkovitch v. Gorilla, Inc., No. 2:15-ev-7806 (WJM), 2017 WL 4005452 (D.N.J. Sept. 12, 2017) 17 Brown v. Maxwell, 929 F.3d 41 (2d Ck 2019) 3, 6 Chambers v. NASCO, Inc., 51
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 →ns To Judge McMahon 16 CONCLUSION 16 Certificate of Service 18 EFTA00029078 --- PAGE BREAK --- TABLE OF AUTHORITIES Cases Benkovitch v. Gorilla, Inc., No. 2:15-ev-7806 (WJM), 2017 WL 4005452 (D.N.J. Sept. 12, 2017) 17 Brown v. Maxwell, 929 F.3d 41 (2d Ck 2019) 3, 6 Chambers v. NASCO, Inc., 51
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 →ns To Judge McMahon 16 CONCLUSION 16 Certificate of Service 18 EFTA00029817 --- PAGE BREAK --- TABLE OF AUTHORITIES Cases Benkovitch v. Gorilla, Inc., No. 2:15-ev-7806 (WJM), 2017 WL 4005452 (D.N.J. Sept. 12, 2017) 17 Brown v. Maxwell, 929 F.3d 41 (2d Ck 2019) 3, 6 Chambers v. NASCO, Inc., 51
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 Gorilla, Inc.

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSONJeffrey Pagliuca
PERSON
Julie K. Brown
PERSON
Boies Schiller
ORGANIZATIONLaura Menninger
PERSON
Michael Cohen
PERSON
Boies Schiller Flexner LLP
ORGANIZATION
Martha Stewart
PERSON
Stephen Hawking
PERSONSecond Circuit
ORGANIZATION
Schiller
PERSONMartindell
PERSON
Boles
PERSONColleen McMahon
PERSONChemical Bank
ORGANIZATION
Giglio
PERSONCohen & Gresser LLP
ORGANIZATIONDistrict Court for the Southern District of New York
ORGANIZATION