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

RPP), 201 1 WL 3738969 (S.D.N.Y. Aug. 22, 2011) 153, 160, 163 United States v. Collins, 409 F. Supp. 3d 228 (S.D.N.Y. 2019) 278 United States v. Concepcion, 983 F.2d 369 (2d Cir. 1992) 252 United States v. Coppa, 267 F.3d 132 (2d Cir. 2001) 274 United States v. Corbett, 750 F.3d 245 (2d Cir. 2014)

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' (

f the alleged conspiracy ... is not an `other' act within the meaning of Rule 404(b); rather, it is part of the very act charged." United States v. Concepcion, 983 F.2d 369, 392 (2d Cir. 1992). The Second Circuit "follows the `inclusionary' approach to 'other crimes, wrongs, or ads' evidence, under which

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

(RPP), 2011 WL 3738969 (S.D.N.Y. Aug. 22, 2011) 153, 160, 163 United States v. Collins, 409 F. Supp. 3d 228 (S.D.N.Y. 2019) 278 United States v. Concepcion, 983 F.2d 369 (2d Cir. 1992) 252 United States v. Coppa, 267 F.3d 132 (2d Cir. 2001) 274 United States v. Corbett, 750 F.3d 245 (2d Cir. 2014)

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

of the alleged conspiracy . is not an `other' act within the meaning of Rule 404(b); rather, it is part of the very act charged." United States v. Concepcion, 983 F.2d 369, 392 (2d Cir. 1992). The Second Circuit "follows the `inclusionary' approach to `other crimes, wrongs, or acts' evidence, under which

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

(RPP), 2011 WL 3738969 (S.D.N.Y. Aug. 22, 2011) 153, 160, 163 United States v. Collins, 409 F. Supp. 3d 228 (S.D.N.Y. 2019) 278 United States v. Concepcion, 983 F.2d 369 (2d Cir. 1992) 252 United States v. Coppa, 267 F.3d 132 (2d Cir. 2001) 274 United States v. Corbett, 750 F.3d 245 (2d Cir. 2014)

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

of the alleged conspiracy . is not an `other' act within the meaning of Rule 404(b); rather, it is part of the very act charged." United States v. Concepcion, 983 F.2d 369, 392 (2d Cir. 1992). The Second Circuit "follows the `inclusionary' approach to `other crimes, wrongs, or acts' evidence, under which

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

(RPP), 2011 WL 3738969 (S.D.N.Y. Aug. 22, 2011) 105, 109, 111 United States v. Collins, 409 F. Supp. 3d 228 (S.D.N.Y. 2019) 186 United States v. Concepcion, 983 F.2d 369 (2d Cir. 1992) 165 United States v. Coppa, 267 F.3d 132 (2d Cir. 2001) 182 United States v. Corbett, 750 F.3d 245 (2d Cir. 2014)

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' (

of the alleged conspiracy . is not an `other' act within the meaning of Rule 404(b); rather, it is part of the very act charged." United States v. Concepcion, 983 F.2d 369, 392 (2d Cir. 1992). The Second Circuit "follows the `inclusionary' approach to `other crimes, wrongs, or acts' evidence, under which

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

(RPP), 2011 WL 3738969 (S.D.N.Y. Aug. 22, 2011) 153, 160, 163 United States v. Collins, 409 F. Supp. 3d 228 (S.D.N.Y. 2019) 278 United States v. Concepcion, 983 F.2d 369 (2d Cir. 1992) 252 United States v. Coppa, 267 F.3d 132 (2d Cir. 2001) 274 United States v. Corbett, 750 F.3d 245 (2d Cir. 2014)

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

f the alleged conspiracy ... is not an `other' act within the meaning of Rule 404(b); rather, it is part of the very act charged." United States v. Concepcion, 983 F.2d 369, 392 (2d Cir. 1992). The Second Circuit "follows the `inclusionary' approach to `other crimes, wrongs, or acts' evidence, under which