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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
s Five and Six under the Due Process Clause, the Fourth Amendment, the Fifth Amendment, and the Second Circuit's decision in Martindell v. TeL and TeL Corp., 594 F.2d 291 (2d Cir. 1979). (Def. Mots. 3 & 11). In particular, the defendant contends that the Government violated the Second Circuit's decision
o unseal discovery materials in the possession of Boies Schiller & Flexner LLP (the "A in connection w
valuate the government's ability to obtain access to materials covered by a protective order. Specifically, in Martindell v. International Tel. and TeL Corp., 594 F.2d 291 (2d Cir. 1979), the government informally—and without use of a grand jury subpoena—sought access to discovery materials from a civil
o unseal discovery materials in the possession of Boies Schiller & Flexner LLP (the "A in connection wi
valuate the government's ability to obtain access to materials covered by a protective order. Specifically, in Martindell v. International Tel. and TeL Corp., 594 F.2d 291 (2d Cir. 1979), the government informally—and without use of a grand jury subpoena—sought access to discovery materials from a civil
o unseal discovery materials in the possession of Boies Schiller & Flexner LLP (the "Application"), in c
valuate the government's ability to obtain access to materials covered by a protective order. Specifically, in Martindell v. International Tel. and TeL Corp., 594 F.2d 291 (2d Cir. 1979), the government informally—and without use of a grand jury subpoena—sought access to discovery materials from a civil
o unseal discovery materials in the possession of Boies Schiller & Flexner LLP the "A in connection wit
valuate the government's ability to obtain access to materials covered by a protective order. Specifically, in Martindell v. International Tel. and TeL Corp., 594 F.2d 291 (2d Cir. 1979), the government informally—and without use of a grand jury subpoena—sought access to discovery materials from a civil
Entities connected to both David Boies and TeL Corp.

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSONSouthern District
LOCATION
George W. Bush
PERSON
Boies Schiller
ORGANIZATION
Department of Justice
ORGANIZATION
Woody Allen
PERSONSweet
PERSONMartindell
PERSONChemical Bank
ORGANIZATION
Boies Schiller & Flexner LLP
ORGANIZATIONSubpoena Duces
PERSONBranzburg v. Hayes
PERSON
Robert W. Sweet
PERSON
Orange
LOCATIONInternational Tel
ORGANIZATIONthe "Litigation"
ORGANIZATIONthe Protective Order
ORGANIZATIONMeserve, Mumper & Hughes
ORGANIZATION