Epstein Secrets

8) 216 United States v. Flagg, 278 F.3d 44 (2d Cir. 2002) 115 United States v. Harrison, 764 F. Supp. 29 (S.D.N.Y. 1991) 72 United States v. Hastings, 461 U.S. 499 (1983) 160 United States v. Heath, 455 F.3d 52 (2d Cir. 2006) 132, 133 United States v. Henderson, 337 F.3d 914 (7th Cir. 2003

r 18, 2018. Shortly thereafter, in or about December or January 2018, the Government indicated to at I that it intended to make document requests. Schiller generally advised the Government that a protective order would govern some of the materials. (Id. at 3). In or about February 2019, approximately t

ore a jury, and finally, as a remedy 109 EFTA00077741 designed to deter illegal conduct.' Coke, 2011 WL 3738969, at '6 (quoting United States v. Hastings, 461 U.S. 499, 505 (1983)). "However, while there are times when a district court may properly find it absolutely necessary[, in order] to preserve

ast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. Aside from

ore a jury, and finally, as a remedy 109 EFTA00039556 designed to deter illegal conduct.' Coke, 2011 WL 3738969, at '6 (quoting United States v. Hastings, 461 U.S. 499, 505 (1983)). "However, while there are times when a district court may properly find it absolutely necessary[, in order] to preserve

ast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. Aside from

1978) 144 United States v. Haqq, 278 F.3d 44 (2d Cir. 2002) 82 United States v. Harrison, 764 F. Supp. 29 (S.D.N.Y. 1991) 50 United States v. Hastings, 461 U.S. 499 (1983) 109 United States v. Heath, 455 F.3d 52 (2d Cir. 2006) 93, 94 United States v. Henderson, 337 F.3d 914 (7th Cir. 2003) 4

bpoenas and Ex Pane Applications for Materials SOW- after opening t mment identified possible victims and their counsel trroiigh ich ina Boies Schiller. (Def. Mem. 3, Ex. E at 2-3). SDNY first cont oies Schiller about its investigation on or about December 18, 2018. Shortly thereafter, in oar Dec

erations validly before a jury, and finally, as a remedy designed to deter illegal conduct.' Coke, 2011 WL 3738969, at *6 (quoting United States v. Hastings, 461 U.S. 499, 505 (1983)). "However, while there are times when a district court may properly find it absolutely necessary[, in order] to preserve

t complying with any of the specific procedures or exceptions provided in the [confidentiality] orders." Id. Here, by contrast, ga on in late 0111 Schiller shortly the na in Februan Miran order, Aside from rank speculation loosely premised on an anonymously sourced news report, the defendant offers n

ore a jury, and finally, as a remedy 109 EFTA00103134 designed to deter illegal conduct.' Coke, 2011 WL 3738969, at '6 (quoting United States v. Hastings, 461 U.S. 499, 505 (1983)). "However, while there are times when a district court may properly find it absolutely necessary[, in order] to preserve

ast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. Aside from