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y prosecution after a second meeting with attorneys, which took place after at least one of Maxwell's depositions. As reported in the Daily News, "David [Boles] was particularly frustrated by the failure to pursue a perjury charge."13 "We have her dead to rights," he said.14 This Court cannot accept without
t foment the Government's investigation. Moreover, the Assistant United States Attorney has represented to this Court that he has no idea what is in Boies Schiller's files, and that for all he knows every witness who was deposed stood on his/her Fifth Amendment rights and refused to answer questions.
utors] who are not merely partisan advocates, but public officials charged with administering justice honestly, fairly and impartially." Morales v. Portuondo, 165 F. Supp. 2d 601, 612 (S.D.N.Y. 2001). 24 EFTA00077599 In turn, this already high standard ratchets up even higher when a prosecutor appears
3, 2017) 24 Martindell v. Intl Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979) 18, 21 McNabb v. United States, 318 U.S. 332 (1943) 20 Morales v. Portuondo, 165 F. Supp. 2d 601 (S.D.N.Y. 2001) 24 Rea v. United States, 350 U.S. 214 (1956) 20 United States v. Bout, 731 F.3d 233 (2d Cir. 2013) 23 Unit
Page: EFTA00028931 →en AUSA appeared before Judge McMahon barely four months later, however, he told her none of this, unequivocally and falsely disavowing any role by Boies Schiller in fomenting the investigation and denying any contacts between Boies Schiller and his office before November 2018. Even though AUSA had
Page: EFTA00028939 →y prosecution after a second meeting with attorneys, which took place after at least one of Maxwell's depositions. As reported in the Daily News, "David [Boles] was particularly frustrated by the failure to pursue a perjury charge.s13 "We have her dead to rights," he said.14 This Court cannot accept without
Page: EFTA00028946 →, 2017) 24 Martindell v. Intl Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979) 18, 21 McNabb v. United States, 318 U.S. 332 (1943) 20 Morales v. Portuondo, 165 F. Supp. 2d 601 2001) 24 Rea v. United States, 350 U.S. 214 (1956) 20 United States v. Bout, 731 F.3d 233 (2d Cir. 2013) 23 United States
Page: EFTA00029102 →en AUSA appeared before Judge McMahon barely four months later, however, he told her none of this, unequivocally and falsely disavowing any role by Boies Schiller in fomenting the investigation and denying any contacts between Boies Schiller and his office before November 2018. Even though AUSA had
Page: EFTA00029110 →y prosecution after a second meeting with attorneys, which took place after at least one of Maxwell's depositions. As reported in the Daily News, "David [Boles] was particularly frustrated by the failure to pursue a perjury charge.s13 "We have her dead to rights," he said.14 This Court cannot accept without
Page: EFTA00029117 →Entities connected to both David Boies and Portuondo

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONSigrid McCawley
PERSON
Bradley Edwards
PERSONJane Doe
PERSONJeffrey Pagliuca
PERSON
Julie K. Brown
PERSON
Boies Schiller
ORGANIZATION
Department of Justice
ORGANIZATIONLaura Menninger
PERSON
Boies Schiller Flexner LLP
ORGANIZATION
Martha Stewart
PERSONSecond Circuit
ORGANIZATION
Stephen Hawking
PERSONSweet
PERSON
Schiller
PERSONMartindell
PERSONColleen McMahon
PERSONLoretta A. Preska
PERSON
Brady
PERSON