entitled to review the underlying documents of the warrants prior to any charges. Giuliani and Toensing asserted their attorney-client privilege with clients may have been violated by the iCloud searches, which investigators disputed, saying they employed a "filter team" to prevent them from seeing information potentially protected by attorney-client privilege. Federal judge J. Paul Oetken days later ruled in favor of investigators regarding the warrant documents and granted their request for a special master to ensure attorney-client privilege was maintained. The special master released more than 3,000 of Giuliani's communications to prosecutors in January 2022, agreeing to withhold forty messages for which Giuliani had asserted "privilege and/or highly personal" status and rejecting 37 such assertions. The New York Times reported in February 2021 that the SDNY was scrutinizing Giuliani's association with Firtash in efforts to discredit the Bidens, and efforts to lobby the Trump administration on behalf of Ukrainian officials and oligarchs. Time reported in May 2021 it had spoken with three unidentified witnesses who said they were questioned by investigators, two of whom said they had worked with Giuliani while cooperating with investigators; one witness said investigators were particularly interested in Giuliani's association with Firtash. United States intelligence community analysis released in March 2021 found that Ukrainian politician Andrii Derkach was among proxies of Russian intelligence who promoted and laundered misleading or unsubstantiated narratives about Biden "to US media organizations, US officials, and prominent US individuals, including some close to former President Trump and his administration". Giuliani met with Derkach in December 2019. In April 2021, Forensic News reported that the SDNY investigation into Giuliani had expanded to include a criminal probe of Derkach and Andrii Artemenko. The New York Times confirmed weeks later that Derkach was the subject of a criminal investigation into foreign interference in the 2020 United States elections. "Federal prosecutors in Brooklyn have been investigating whether several Ukrainian officials helped orchestrate a wide-ranging plan to meddle in the 2020 presidential campaign, including using Rudolph W. Giuliani to spread their misleading claims about President Biden and tilt the election in Donald J. Trump's favor," the Times reported. On June 8, 2021, CNN uncovered exclusive audio of a 2019 phone call from Giuliani to Ukraine, stating that "Rudy Giuliani relentlessly pressured and coaxed the Ukrainian government in 2019 to investigate baseless conspiracies about then-candidate Joe Biden." The New York Times reported in August 2022 that SDNY was