Epstein Secrets

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' (

31 (approving of similar precautions when introducing evidence of a defendant's prior felony conviction); Pizarro, 2018 WL 1737236, at *7; see also Zafiro, 506 U.S. at 540 ("[J]uries are presumed to follow their instructions." (citation and internal quotation marks omitted)). There is every reason to

o sever defendants, rather than counts, the Supreme Court's construction of Rule 14(a) applies in either case. See Page, 657 F.3d at 129 (relying on Zafiro); United States v. Gracesqui, No. 10 Cr. 74 (PKC), 2015 WL 5231168, at *4 n.2 (S.D.N.Y. Sept 8, 2015), afd, 730 F. App'x 25 (2d Cir. 2018) (citing

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

31 (approving of similar precautions when introducing evidence of a defendant's prior felony conviction); Pizarro, 2018 WL 1737236, at *7; see also Zafiro, 506 U.S. at 540 ("[J]uries are presumed to follow their instructions." (citation and internal quotation marks omitted)). There is every reason to

o sever defendants, rather than counts, the Supreme Court's construction of Rule 14(a) applies in either case. See Page, 657 F.3d at 129 (relying on Zafiro); United States v. Gracesqui, No. 10 Cr. 74 (PKC), 2015 WL 5231168, at *4 n.2 (S.D.N.Y. Sept. 8, 2015), aff'd, 730 F. App'x 25 (2d Cir. 2018) (citi

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

31 (approving of similar precautions when introducing evidence of a defendant's prior felony conviction); Pizarro, 2018 WL 1737236, at *7; see also Zafiro, 506 U.S. at 540 ("[J]uries are presumed to follow their instructions." (citation and internal quotation marks omitted)). There is every reason to

o sever defendants, rather than counts, the Supreme Court's construction of Rule 14(a) applies in either case. See Page, 657 F.3d at 129 (relying on Zafiro); United States v. Gracesqui, No. 10 Cr. 74 (PKC), 2015 WL 5231168, at *4 n.2 (S.D.N.Y. Sept. 8, 2015), aff'd, 730 F. App'x 25 (2d Cir. 2018) (citi

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' (

31 (approving of similar precautions when introducing evidence of a defendant's prior felony conviction); Pizarro, 2018 WL 1737236, at *7; see also Zafiro, 506 U.S. at 540 ("[J]uries are presumed to follow their instructions." (citation and internal quotation marks omitted)). There is every reason to

o sever defendants, rather than counts, the Supreme Court's construction of Rule 14(a) applies in either case. See Page, 657 F.3d at 129 (relying on Zafiro); United States v. Gracesqui, No. 10 Cr. 74 (PKC), 2015 WL 5231168, at *4 n.2 (S.D.N.Y. Sept. 8, 2015), aff'd, 730 F. App'x 25 (2d Cir. 2018) (citi

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

31 (approving of similar precautions when introducing evidence of a defendant's prior felony conviction); Pizarro, 2018 WL 1737236, at *7; see also Zafiro, 506 U.S. at 540 ("[J]uries are presumed to follow their instructions." (citation and internal quotation marks omitted)). There is every reason to

o sever defendants, rather than counts, the Supreme Court's construction of Rule 14(a) applies in either case. See Page, 657 F.3d at 129 (relying on Zafiro); United States v. Gracesqui, No. 10 Cr. 74 (PKC), 2015 WL 5231168, at *4 n.2 (S.D.N.Y. Sept. 8, 2015), aff'd, 730 F. App'x 25 (2d Cir. 2018) (citi