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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
ges, based on a New York Daily News article, that Boies Schiller and the Government colluded starting in
ited States v. Biaggi, 909 F.2d 662 (2d Cir. 1990) 298, 300 United States v. Bin Laden, 91 F. Supp. 2d 600 (S.D.N.Y. 2000) 240 United States v. Birney, 686 F.2d 102 (2d Cir. 1982) 61, 65 United States v. Birrell, 470 F.2d 113 (2d Cir. 1972) 183 EFTA00099951 United States v. Blakney, 941 F.
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
o old, at most the door is barely ajar."). Substantial prejudice is just that—substantial, actual, non-speculative prejudice. See United States v. Birney, 686 F.2d 102, 105-06 (2d Cir. 1982) (a defendant's "proof of prejudice must be definite and not speculative"); see also United States v. Henderson,
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
o old, at most the door is barely ajar."). Substantial prejudice is just that—substantial, actual, non-speculative prejudice. See United States v. Birney, 686 F.2d 102, 105-06 (2d Cir. 1982) (a defendant's "proof of prejudice must be definite and not speculative"); see also United States v. Henderson,
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
Biaggi, 909 F.2d 662 (2d Cir. 1990) 205, 208 ix EFTA00095076 United States v. Bin Laden, 91 F. Supp. 2d 600 (S.D.N.Y. 2000) United States v. Birney, 686 F.2d 102 (2d Cir. 1982) United States v. Birrell, 159 43, 45 470 F.2d 113 (2d Cir. 1972) 122 United States v. Blakney, 941 F.2d 114 (2d
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
ited States v. Biaggi, 909 F.2d 662 (2d Cir. 1990) 298, 300 United States v. Bin Laden, 91 F. Supp. 2d 600 (S.D.N.Y. 2000) 240 United States v. Birney, 686 F.2d 102 (2d Cir. 1982) 61, 65 United States v. Bbrell, 470 F.2d 113 (2d Cir. 1972) 183 EFTA00103009 United States v. Blakney, 941 F.2
Entities connected to both David Boies and Birney

Jeffrey Epstein
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Ghislaine Maxwell
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Bradley Edwards
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Prince Andrew
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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
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Department of Justice
ORGANIZATION
Boies Schiller
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Colorado
LOCATIONMartin Weinberg
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Michael Jackson
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Southern District of New York
ORGANIZATION
Lesley Groff
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