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nited States, 138 S. Ct. 2206 (2018). 2$ Doe v. Indyke, Case No., 20-cv-00484 (S.D.N.Y.) 6 v. Maxwell,
897, 923 (1984). Here, as explained in Maxwell's due process motion to suppress and the reply in support thereof, the government misled Chief Judge McMahon to modify the Protective Order and authorize the subpoena to Boies Schiller. The good faith doctrine does not apply when the government acts in ob
nited States, 138 S. Ct. 2206 (2018). 2$ Doe v. Indyke, Case No., 20-cv-00484 (S.D.N.Y.) 6 v. Maxwell,
897, 923 (1984). Here, as explained in Maxwell's due process motion to suppress and the reply in support thereof, the government misled Chief Judge McMahon to modify the Protective Order and authorize the subpoena to Boies Schiller. The good faith doctrine does not apply when the government acts in ob
ted States, 138 S. Ct. 2206 (2018). 2, 3 Doe v. Indyke, Case No., 20-cv-00484 (S.D.N.Y.) 6 Giuffre v.
897, 923 (1984). Here, as explained in Maxwell's due process motion to suppress and the reply in support thereof, the government misled Chief Judge McMahon to modify the Giuffre Protective Order and authorize the subpoena to Boies Schiller. The good faith doctrine does not apply when the government act
73- DOE, JANE, KPF-DCF Plaintiff, - against - INDYKE, et al., : New York, New York June 24, 2020 De
ll that fast. With respect to bench trials, there are some judges who are venturing into the world of holding remote bench trials. I believe Judge McMahon has one scheduled. There are some others who have been making efforts and figuring out remote platforms that will work. And there's also the possi
to intervene and stay the proceedings in Doe v. Indyke, No. 20 Civ. 484 (JGK), while the Government has
ces the Instant Investigation in 2018 65 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials 66 6. Proceedings before Chief Judge McMahon 68 a. March 26, 2019 Hearing 68 b. April 9, 2019 Hearing 70 EFTA00103000 c. Chief Judge McMahon's Memorandum and Order 71 7. Magistrate Judge
to intervene and stay the proceedings in Doe v. Indyke, No. 20 Civ. 484 (JGK), while the Government has
der is unreasonable where, as here, the protective order is on its face temporary or limited." (Id. at 3-4). 6. Proceedings before a. Chief Judge McMahon Mich 26,2019 Hearing Judge Sweet passed away in March 2019 before ruling on the Government's application. After Judge Sweet's death, but before the
to intervene and stay the proceedings in Doe v. Indyke, No. 20 Civ. 484 (JGK), while the Government has
ces the Instant Investigation in 2018 65 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials 66 6. Proceedings before Chief Judge McMahon 68 a. March 26, 2019 Hearing 68 b. April 9, 2019 Hearing 70 EFTA00077607 c. Chief Judge McMahon's Memorandum and Order 71 7. Magistrate Judge
to intervene and stay the proceedings in Doe v. Indyke, No. 20 Civ. 484 (JGK), while the Government has
ces the Instant Investigation in 2018 65 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials 66 6. Proceedings before Chief Judge McMahon 68 a. March 26, 2019 Hearing 68 b. April 9, 2019 Hearing 70 EFTA00039422 c. Chief Judge McMahon's Memorandum and Order 71 7. Magistrate Judge
to intervene and stay the proceedings in Doe v. Indyke, No. 20 Civ. 484 (JGK), while the Government has
eedin s before 5. The USAO-SDNY's Sub.. nas and Ex Pane Applications for Materials 66 a. M 68 b. April ', 70 EFTA00095068 c. Chief Judge McMahon's Memorandum and Order 71 7. &OAS% 74 8. Unsealing of Maxwell's Depositions 74 9. The New York Daily News Article 75 B. The Defendant's Sup
--- TABLE OF AUTHORITIES Cases Appeal ofHughes, 633 F.2d 282 (3d Cir. 1980) 2 Carpenter v. United States, 138 S. Ct. 2206 (2018). 2, 3 Doe v. Indyke, Case No., 20-cv-00484 (S.D.N.Y.) 6 Giuffre v. Maxwell, 325 F. Supp. 3d 428 (S.D.N.Y. 2018) 6 Matter of Grand Jury Subpoena Duces Tecum Dated Feb
Page: EFTA00018999 →897, 923 (1984). Here, as explained in Maxwell's due process motion to suppress and the reply in support thereof, the government misled Chief Judge McMahon to modify the Giuffre Protective Order and authorize the subpoena to Boies Schiller. The good faith doctrine does not apply when the government act
Page: EFTA00019006 →Entities connected to both Darren Indyke and Colleen McMahon

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Lesley Groff
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Marc Rich
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Bella Klein
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Newark
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Julie K. Brown
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Woody Allen
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Alan Dershowitz
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