Epstein Secrets

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

ges, based on a New York Daily News article, that Boies Schiller and the Government colluded starting in

nna Vljua, No. 15 Cr. 240, 2016 WL 107841 (N.D. Tex. Jan. 11, 2016) 22 United States v. Marion, 404 U.S. 307 (1971) 59, 63, 72 United States v. Markiewicz, 978 F.2d 786 (2d Cir. 1992) 178, 180, 187,198 United States v. Martin, 426 F.3d 68 (2d Cir. 2005) 167 United States v. Martinez, No. 92 Cr. (

Boies it was issued. The materials provided by Boies Schiller inclnin addition tIl inscripts of Maxwell and other individuals, materials proday N/14!I

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' (

case, the "answers associated with the questions posed may be insufficient as a matter of law to support the perjury conviction." United States v. Markiewicz, 978 F.2d 786, 808 (2d Cir. 1992) (quoting Lighte, 782 F.2d at 375). For instance, in Lighte, a case involving post-conviction appellate review, the

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

mma Vijua, No. 15 Cr. 240, 2016 WL 107841 (N.D. Tex. Jan. 11, 2016) 22 United States v. Marion, 404 U.S. 307 (1971) 59, 63, 72 United States v. Markiewicz, 978 F.2d 786 (2d Cir. 1992) 178, 180, 187, 198 United States v. Martin, 426 F.3d 68 (2d Cir. 2005) 167 United States v. Martinez, No. 92 Cr.

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"' (

y contrast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. A

case, the "answers associated with the questions posed may be insufficient as a matter of law to support the perjury conviction." United States v. Markiewicz, 978 F.2d 786, 808 (2d Cir. 1992) (quoting Lighte, 782 F.2d at 375). For instance, in Lighte, a case involving post-conviction appellate review, the

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

mma Vijua, No. 15 Cr. 240, 2016 WL 107841 (N.D. Tex. Jan. 11, 2016) 22 United States v. Marion, 404 U.S. 307 (1971) 59, 63, 72 United States v. Markiewicz, 978 F.2d 786 (2d Cir. 1992) 178, 180, 187, 198 United States v. Martin, 426 F.3d 68 (2d Cir. 2005) 167 United States v. Martinez, No. 92 Cr.

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"' (

y contrast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. A

case, the "answers associated with the questions posed may be insufficient as a matter of law to support the perjury conviction." United States v. Markiewicz, 978 F.2d 786, 808 (2d Cir. 1992) (quoting Lighte, 782 F.2d at 375). For instance, in Lighte, a case involving post-conviction appellate review, the

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

368 (S.D.N.Y. 2010) 175 United States v. Marcus, 628 F.3d 36 (2d Cir. 2010) 163 United States v. Marion, 404 U.S. 307 (1971) United States v. Markiewicz, 42, 44, 49 978 F.2d 786 (2d Cir. 1992) 120, 121, 125, 134 United States v. Martin, 426 F.3d 68 (2d Cir. 2005) 113 United States v. Martinez,

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' (

a case, the "answers associated with the questions posed may be insufficient as a matter of law to support the perjury conviction." United States v. Markiewicz, 978 F.2d 786, 808 (2d Cir. 1992) (quoting Lighte, 782 F.2d at 375). For instance, in Lighte, a case involving post-conviction appellate review, th

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

mma Vijua, No. 15 Cr. 240, 2016 WL 107841 (N.D. Tex. Jan. 11, 2016) 22 United States v. Marion, 404 U.S. 307 (1971) 59, 63, 72 United States v. Markiewicz, 978 F.2d 786 (2d Cir. 1992) 178, 180, 187, 198 United States v. Martin, 426 F.3d 68 (2d Cir. 2005) 167 United States v. Martinez, No. 92 Cr.

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"'

y contrast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. A

case, the "answers associated with the questions posed may be insufficient as a matter of law to support the perjury conviction." United States v. Markiewicz, 978 F.2d 786, 808 (2d Cir. 1992) (quoting Lighte, 782 F.2d at 375). For instance, in Lighte, a case involving post-conviction appellate review, the