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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
full compliance.33 (Exs. 8 & 9). Accordingly, the Government applied a pate and under seal to each relevant court (Judge Sweet and Magistrate Judge Sarah Netbum, respectively) to request that each court modify the respective protective orders to permit compliance with the subpoenas. (Def. Mot. 3, Ex. C). Fo
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
full compliance.33 (Exs. 8 & 9). Accordingly, the Government applied a pate and under seal to each relevant court (Judge Sweet and Magistrate Judge Sarah Netbum, respectively) to request that each court modify the respective protective orders to permit compliance with the subpoenas. (Def. Mot. 3, Ex. C). Fo
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
ll compliance.33 (Exs. 8 & 9). Accordingly, the Government applied ex parte and under seal to each relevant court (Judge Sweet and Magistrate Judge Sarah Netbum, respectively) to request that each court modify the respective protective orders to permit compliance with the subpoenas. (Def. Mot. 3, Ex. C). Fo
s. SDNY_GM_00000904 through SDNY_GM_00000905) to Boies Schiller & Flexner LLP, and production of the ent
Page: EFTA00030904 →nt maintains that the "Confidential" designation of the Unsealing Materials is appropriate because Chief Judge Colleen McMahon and Magistrate Judge Sarah Netbum have ordered that the Unsealing Materials remain under seal. The only exceptions to those sealing orders are the production of Chief Judge McMahon'
Page: EFTA00030904 →o unseal discovery materials in the possession of Boies Schiller & Flexner LLP (the "Application"), in c
The Silvio J. Mediu Building One Saint Andrew's Plaza New York. New York 10007 February 28, 2019 TO BE FILED UNDER SEAL VIA EMAIL The Honorable Sarah Netbum United States District Court Southern District of New York United States Courthouse New York, New York 10007 Re: In re Application to Unseal Ci
Entities connected to both David Boies and Sarah Netbum

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSON
Virginia Giuffre
PERSON
United States
LOCATIONthe Southern District
LOCATIONJane Doe
PERSON
George Mitchell
PERSON
George W. Bush
PERSONMaria Farmer
PERSONDarren Indyke
PERSON
Julie K. Brown
PERSON
Department of Justice
ORGANIZATION
Colorado
LOCATIONMartin Weinberg
PERSON
Michael Jackson
PERSON
Southern District of New York
ORGANIZATION
Lesley Groff
PERSON
Supreme Court
ORGANIZATION