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EFTA00100287
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 acts in objective bad faith. C. The gover
teed Maxwell notice and an opportunity to be heard, 594 F.2d at 294, as did the Protective Order, Mot. 3, Ex. A, 1 14. But Maxwell had no idea that the Giuffre Protective Order had been modified behind her back until she was indicted and the government disclosed the 90,000 pages of material it obtained from Boies Schiller.2
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