{
  "document_metadata": {
    "page_number": "98",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 98 of 239\n\nBank, of course, as noted above, the subpoena recipient produced materials to a prosecutor in direct violation of the relevant protective order, without seeking a modification of the protective order and without any court authorization to do so. 154 F.R.D. at 93. Moreover, in that case, the District Attorney seemingly opened its investigation and issued the subpoena in direct response to information provided by the subpoena recipient who was then a party to civil litigation. Id.\n\nThe Government responded to Chief Judge McMahon by explaining its contacts with Boies Schiller in connection with the instant (and only) investigation it had opened on Epstein, that is, the investigation prompted by, and opened following, public reporting on Epstein in November 2018. In particular, the Government explained that the USAO-SDNY opened an investigation first, on either November 30, 2018 or December 3, 2018, and then made contact with Boies Schiller shortly thereafter. (Def. Mot. 3, Ex. E at 2-3). In this respect, the Government further explained that the USAO-SDNY, after opening the investigation, had endeavored to identify counsel who represented victims or witnesses in public filings or media reports, which included Boies Schiller, noting that \"[w]ith respect to Boies Schiller in particular, we quickly came to learn during the investigation that they had at the time either active or recently completed civil litigation\" and indicated that the USAO-SDNY intended to make document requests. (Id.). The Government also noted that, unlike in Chemical Bank, here Boies Schiller had informed the Government that it would be unable to comply with the subpoena in light of the protective order. (Id. (noting that Boies Schiller \"generally advised us that they believed there was a protective order that would govern at least some of the materials, and that is why we ultimately made the application to the Court.\")).\n\nc. Chief Judge McMahon's Memorandum and Order",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 98 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Bank, of course, as noted above, the subpoena recipient produced materials to a prosecutor in direct violation of the relevant protective order, without seeking a modification of the protective order and without any court authorization to do so. 154 F.R.D. at 93. Moreover, in that case, the District Attorney seemingly opened its investigation and issued the subpoena in direct response to information provided by the subpoena recipient who was then a party to civil litigation. Id.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Government responded to Chief Judge McMahon by explaining its contacts with Boies Schiller in connection with the instant (and only) investigation it had opened on Epstein, that is, the investigation prompted by, and opened following, public reporting on Epstein in November 2018. In particular, the Government explained that the USAO-SDNY opened an investigation first, on either November 30, 2018 or December 3, 2018, and then made contact with Boies Schiller shortly thereafter. (Def. Mot. 3, Ex. E at 2-3). In this respect, the Government further explained that the USAO-SDNY, after opening the investigation, had endeavored to identify counsel who represented victims or witnesses in public filings or media reports, which included Boies Schiller, noting that \"[w]ith respect to Boies Schiller in particular, we quickly came to learn during the investigation that they had at the time either active or recently completed civil litigation\" and indicated that the USAO-SDNY intended to make document requests. (Id.). The Government also noted that, unlike in Chemical Bank, here Boies Schiller had informed the Government that it would be unable to comply with the subpoena in light of the protective order. (Id. (noting that Boies Schiller \"generally advised us that they believed there was a protective order that would govern at least some of the materials, and that is why we ultimately made the application to the Court.\")).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "c. Chief Judge McMahon's Memorandum and Order",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "71",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003032",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "McMahon"
    ],
    "organizations": [
      "Boies Schiller",
      "USAO-SDNY",
      "Chemical Bank"
    ],
    "locations": [],
    "dates": [
      "November 30, 2018",
      "December 3, 2018",
      "04/16/21",
      "November 2018"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "204",
      "98",
      "239",
      "154 F.R.D. at 93",
      "Def. Mot. 3, Ex. E at 2-3",
      "DOJ-OGR-00003032"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case involving Epstein. The text is mostly printed, with no handwritten content or stamps visible."
}