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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
secution for crimes that pre- or post-dated the period covered by the agreement. The Government is aware of no such authority. See United States v. Hallahan, 756 F.3d 962, 974 (7th Cir. 2014) (rejecting defense argument that plea agreement barred prosecution for subsequent bail jumping, and, in interpret
7 F. Supp. 140 (S.D.N.Y. 1972) 300 United States v. Halkbank, No. 15 Cr. 867 (RMB), 2020 WL 5849512 (S.D.N.Y. Oct. 1, 2020) 261 United States v. Hallahan, 756 F.3d 962 (7th Cir. 2014) 19 United States v. Halper, 590 F.2d 422 (2d Cir. 1978) 216 United States v. Flagg, 278 F.3d 44 (2d Cir. 2002)
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
secution for crimes that pre- or post-dated the period covered by the agreement. The Government is aware of no such authority. See United States v. Hallahan, 756 F.3d 962, 974 (7th Cir. 2014) (rejecting defense argument that plea agreement barred prosecution for subsequent bail jumping, and, in interpret
7 F. Supp. 140 (S.D.N.Y. 1972) 300 United States v. Halkbank, No. 15 Cr. 867 (RMB), 2020 WL 5849512 (S.D.N.Y. Oct. I, 2020) 261 United States v. Hallahan, 756 F.3d 962 (7th Cir. 2014) 19 United States v. Halper, 590 F.2d 422 (2d Cir. 1978) 216 United States v. Haqq, 278 F.3d 44 (2d Cir. 2002) 1
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
secution for crimes that pre- or post-dated the period covered by the agreement. The Government is aware of no such authority. See United States v. Hallahan, 756 F.3d 962, 974 (7th Cir. 2014) (rejecting defense argument that plea agreement barred prosecution for subsequent bail jumping, and, in interpret
7 F. Supp. 140 (S.D.N.Y. 1972) 300 United States v. Halkbank, No. 15 Cr. 867 (RMB), 2020 WL 5849512 (S.D.N.Y. Oct. I, 2020) 261 United States v. Hallahan, 756 F.3d 962 (7th Cir. 2014) 19 United States v. Halper, 590 F.2d 422 (2d Cir. 1978) 216 United States v. Haqq, 278 F.3d 44 (2d Cir. 2002) 1
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
secution for crimes that pre- or post-dated the period covered by the agreement. The Government is aware of no such authority. See United States v. Hallahan, 756 F.3d 962, 974 (7th Cir. 2014) (rejecting defense argument that plea agreement barred prosecution for subsequent bail jumping, and, in interpret
337 F. Supp. 140 (S.D.N.Y. 1972) 208 United States v. Halkbank, 15 Cr. 867 (RMB), 2020 WL 5849512 (S.D.N.Y. Oct. 1, 2020) 170 United States v. Hallahan, 756 F.3d 962 (7th Cir. 2014) 16 United States v. Halper, 590 F.2d 422 (2d Cir. 1978) 144 United States v. Haqq, 278 F.3d 44 (2d Cir. 2002) 8
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
secution for crimes that pre- or post-dated the period covered by the agreement. The Government is aware of no such authority. See United States v. Hallahan, 756 F.3d 962, 974 (7th Cir. 2014) (rejecting defense argument that plea agreement barred prosecution for subsequent bail jumping, and, in interpret
7 F. Supp. 140 (S.D.N.Y. 1972) 300 United States v. Halkbank, No. 15 Cr. 867 (RMB), 2020 WL 5849512 (S.D.N.Y. Oct. I, 2020) 261 United States v. Hallahan, 756 F.3d 962 (7th Cir. 2014) 19 United States v. Halper, 590 F.2d 422 (2d Cir. 1978) 216 United States v. Haqq, 278 F.3d 44 (2d Cir. 2002)
Entities connected to both David Boies and Hallahan

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
PERSON
Department of Justice
ORGANIZATION
Boies Schiller
ORGANIZATION
Colorado
LOCATIONMartin Weinberg
PERSON
Michael Jackson
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Southern District of New York
ORGANIZATION
Lesley Groff
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