MEMY-1805 harvest: vision-joined (part 41)

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vision-joined/ds9-unparsed-01/8f83e85af64ab3691383e0879b9cd2c6f703f5828528e1976485883bc385896d.md

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+Mod AO 442(09/13) Arrest Warrant
+AUSA Name & Telno:
+, 212-637-2225
+UNITED STATES DISTRICT COURT
+for the
+Southern District of New York
+United States of America
+V.
+Case No.
+Ghislaine Maxwell
+Defendant
+ARREST WARRANT
+To:
+Any authorized law enforcement officer
+YOU ARE COMMANDED to arrest and bring before a United States magistrate judge without unnecessary delay
+(name of person to be arrested)K Ghislaine Maxwell
+who is accused of an offense or violation based on the following document filed with the court:
+• Indictment
+• Superseding Indictment • Information
+• Probation Violation Petition • Supervised Release Violation Petition
+• Superseding Information • Complaint
+• Violation NoticeD Order of the Court
+This offense is briefly described as follows:
+Title 18, United States Code, Section 371 (conspiracy to entice minors)
+Title 18, United States Code, Sections 2422 and 2 (enticement of a minor)
+Tie 18, United States Code Section s2423(a ara to rapport minors)
+Title 18, United States Code, Section 1623 (perjury)
+Date:
+06/29/2020
+Sher Mugaret conn
+Issuing officer's signature
+City and state:
+White Plains, NY
+Hon. Lisa Margaret Smith, U.S. Magistrate Judge
+Printed name and title
+Return
+This warrant was received on (date)
+, and the person was arrested on (dase)
+at (city and state)
+Date:
+Arresting officer's signature
+Printed name and title
+EFTA00073462

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vision-joined/ds9-unparsed-01/8fb32ffe497e798763652d9ed2ef526e82173bcafec7ccaf37b35c69938d6b66.md

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+Jeffrey Epstein Archives
+Jeffrey Epstein Story in the New York Times Is Very, Very
+Strange
+We keep re-reading the story on Jeffrey Epstein in the New York Times, trying to decide what it is that
+makes it read so queer. It's not just that it took the paper so long to come around with a story. It's not just
+that this story appears now with almost no breaking news hook. There's something weird about the
+structure of the thing.
+The headline. "Questions of Preferential Treatment Are Raised in Sex Case Against Money Manager" We're
+already off onto a meta-story story here. A more straight forward report would be headed "Accusations of
+Sex Crimes Made Against Money Manager." The Times, however, goes with the secondary question—
+whether or not Epstein is getting preferential treatment in the case.
+The lede. Abby Goodnough begins not with the charges against Epstein but with the image of police
+sneaking around through his garbage and phone records. This is how you might begin a screenplay about
+Epstein but in a news story, well, it has the effect of pushing Epstein's alleged misdeeds into the
+background.
+The body. In what follows, the Times devotes a total of 437 words to the allegations against Epstein,
+around 250 words to allegations that Epstein received preferential treatment and around 236 words to
+quoting or summarizing the arguments of Epstein's lawyers. So, if the story itself is pretty balanced between
+the actual allegations and the allegations about the allegations, why does the headline and the lead imply
+the real story here is about the treatment of Epstein rather than what he's alleged to have done?
+Maybe the possibility of a corrupt prosecution is more interesting to the Times but surely it deserves to be
+placed behind the coverage of the allegations themselves. Are ink-and-paper journalists so convinced that
+the "cover-up is worse than the crime" that they don't care so much about the crimes anymore?
+Look. We're glad the Times finally decided the story was fit to print-although we wonder what could have
+possibly taken them so long. And what's more, we wonder why they're coverage is so, well, poorly focused.
+[DealBreaker's Jeff Epstein Archive]
+Posted by John Carney at 12:12 PM on September 05, 2006 | Permalink | Comments (0) | TrackBacks (0)
+As It Turns Out, Jeffrey Epstein Actually Exists
+There were a few moments now and then when we started to wonder whether we were hallucinating
+Jeffrey Epstein. After all, if the New York Times wasn't reporting on the story it couldn't really be happening,
+could it? This is the paper that printed dozens upon dozens of articles on the Augusta National Golf Club's
+exclusion of women-complete with howler headlines breaking non-news such as "CBS Refuses Not To
+Show Masters"-and if they've got room for that sort of thing, surely at some point over the summer they
+might have found room to print one story about the prostitution charges against the mysterious money
+So you can imagine our relief Sunday morning when we woke up to discover that we had been right all
+along. The Jeffrey Epstein story is happening. It is news worthy. It is fit to print. And we know all this
+because it is, finally, in the New York Times.
+EFTA00067272
+
+Case Against
+Posted by
+Permalink |
+Questions of Preferential Treatment Are Raised in Sex
+Money Manager [New York Times]
+John Carney at 10:19 AM on September 05, 2006 |
+Comments (4) | TrackBacks (0)
+S.
+Jeffrey
+His Campaign Check
+¡Epstein's Taint: Spitzer Returns
+Jeff Epstein cannot seem to catch a break. Yesterday more New Mexican politicians dumped his campaign
+contributions. Today the New York Sun reports that Eliot Spitzer sent back a whopping $50,000 contribution
+from Epstein. When even politicians don't want your money, you know you are in serious trouble. And
+Epstein cannot even call his usual masseuses to relieve the stress.
+Candidate Spitzer Returns $100,000 In Tainted Campaign Contributions [New York Sun]
+Posted by John Carney at 10:09 AM on August 18, 2006 | Permalink | Comments (0) | TrackBacks (0)
+More New Mexican Pols Dumping Epstein Money
+The ickieness of Jeff Epstein crept quietly into New Mexican politics but it's now being loudly kicked out.
+New Mexico's Democratic Land Commissioner candidate Jim Baca announced earlier today in DealBreaker's
+comment section that he will donate to charity the money his campaign got from Epstein. Santa Fe Sheriff
+Greg Solano-who got $2000 from Epstein-has decided to make $1000 donations to two local charities,
+despite the fact that his primary campaign left him in debt. Both men have reportedly denied ever having
+met Epstein.
+Baca to return billionaire's cash [The New Mexican]
+Sheriff Greg Solano's DealBreaker Comment [DealBreaker]
+Jim Baca's DealBreaker Comment [DealBreaker]
+Posted by John Carney at 02:35 PM on August 17, 2006 | Permalink | Comments (O) | TrackBacks (0)
+Does Ken Stevens Have A Secret? The Jeffrey Epstein
+Connection
+The Limited Brands-the parent company of Victoria's Secret, Limited Express and Bath & Bodyworks—is
+losing its CFO, Ken Stevens. After only two months in the post, Stevens is resigning to "spend more time
+with his family."
+EFTA00067273
+
+Here's another, completely speculative theory sparked by Stevens lame explanation. The
+CEO of the Limited is Les Wexner, who just happens to be Jeffrey Epstein's only confirmed client. We can
+magine that these days it would be uncomfortable running the financial aspects of a company whose chie
+vas so closely connected with Epstein. Is there a connection between Epstein's legal troubles and Stevens
+resignation? Unfortunately, Stevens did not return calls from DealBreaker seeking clarification.
+Limited Brands: "Who Has a Secret?" [10Q Detective]
+Posted by John Carney at 01:00 PM on August 17, 2006 | Permalink | Comments (2) | TrackBacks (0)
+Why I'm Keeping Jeffrey Epstein's Money: Sheriff Greg Solano
+Explains
+The short answer: because being sheriff makes him poor.
+Steve Terrell, political reporter for The Santa Fe New Mexican called me tonight to get my comments on the
+indictment. He asked me whether I would be returning the money he donated to my campaign. I received
+the $2000 donation in August of 2005 and used it for the June 2006 Primary Campaign. I completed the
+June Primary having spent all donations and actually ending the campaign over $2000 in debt. That debt
+means that the remaining money was paid out of my pocket. So the short answer is there is nothing left to
+return. It is now nearly a year since I recieved the donation and the campaign for Sheriff is over and done.
+As I have no Republican opponent I will not have to wage a General Election Campaign. I did not plan on
+any further fundraising although some who read in my campaign reports that I had ended with a debt
+offered to raise some additional money to clear the debt. If I did have the money I probably would return it
+or give it to a charity as the $2000, returned to Mr. Epstein who is a billionaire would probably not mean
+Billionaire Donor In Palm Beach Sex Scandal [Sheriff Greg Salono Blog]
+Posted by John Carney at 10:09 AM on August 17, 2006 | Permalink | Comments (5) | TrackBacks (0)
+Jeffrey Epstein's Legal Immunity: Maybe It's Politics
+Jeffrey Epstein has some powerful friends but it seems he's made some pretty vocal enemies as well. Last
+night Bill O'Reilly apparently delivered his "Memo" on the subject of the Epstein prosecution-charging
+prosecutor Krischer with political bias. The gist of it is that Krischer was the prosecutor responsible for
+bringing charges of drug abuse against Rush Limbaugh, but now seems to be going easy on Epstein. You
+get the picture tough on Republicans, easy on Democrats. Here's O'Reilly on the Epstein situation.
+Politics does play a role in local prosecutions, no question about it. And when you examine how much time
+and effort state attorney Krischer put into trying to ruin Rush Limbaugh as opposed to what he's doing now
+in the far more serious case of Jeffrey Epstein? Many, many questions come to mind and none of those
+questions reflect well on Barry Krischer.
+Ugh. We hope this isn't what is going on. There's nothing more boring than a debate about political biases.
+Another Outrageous Legal Situation in Florida [FoxNews.Com]
+EFTA00067274
+
+Posted by John Carney at 04:06 PM on August 16, 2006 | Permalink | Comments (0) | TrackBacks (0)
+Epstein's Defense Tactic-Smear Everyone
+It's tough to tell from our safe remove in lower Manhattan exactly what's been going on down in Palm
+Beach between the prosecutors and the police. The Florida prosecutors didn't charge Jeffrey Epstein
+directly-perhaps because Epstein's legal dream team intimidated them convinced them that the girls police
+had interviewed were not credible witnesses-and the grand jury chose only to indict Epstein for solicitation.
+While that charge is still a felony, it is far less serious than the sex with minors charges police had sought.
+What's more, the grand jury neglected to charge Epstein's assistant |
+had an instrumental role in setting up the sessions with underage girls, with anything at all. Frustrated with
+the local prosecutors, the police have now turned the case over to the FBI in an attempt to have federal
+prosecutors bring more serious charges.
+So, of course, Epstein's lawyers have gone beyond smearing the girls who allegedly spent time nearly naked
+rubbing lotion into the money manager while he rubbed one out into a towel. They are also attacking Palm
+Beach Police Chief Epstein, Michael Reiter, 53. They've referred to the chief's pursuit of Epstein as
+"craziness," and characterized his dispute with prosecutors as "childish." Someone has also been spreading
+rumors that Reiter is involved in a "messy divorce"—which is disgusting non-sequitur that seems clearly
+intended to intimidate Reiter into back off the case.
+As we said, it's tough to tell exactly what is going on from this remove. But the Palm Beach Post, which is
+one of the few mainstream newspapers covering this story in any detail, recently printed a story that seems
+to refute the smears against Reiter. It paints as a well-respected professional. Oddly enough, however, the
+prosecutor Reiter has sought to have removed from the case, State Attorney Barry Krischer, also seems to
+be well respected. As we said, it's hard to tell what is going on down in the world of Palm Beach.
+But what's not hard to see is that the Epstein defense has developed a pattern-painting everyone accusing
+Epstein of crimes as disrespectable.
+Police chief's reputation helps discredit attacks [Palm Beach Post]
+Posted by John Carney at 03:27 PM on August 16, 2006 | Permalink | Comments (O) | TrackBacks (0)
+Jeffrey Epstein Sex Scandal Roils New Mexico Politics
+Stick another pin into your map tracking the scandal surrounding Jeffrey Epstein. The governor of New
+Mexico, Bill Richardson, is donating the campaign contributions he got from Epstein to local charities, a New
+Mexico newspaper is reporting.
+Epstein is said to own one of the largest private home in New Mexico, a 26,700-square-foot hilltop fortress
+mansion on his Zorro ranch.
+Epstein's been pretty active in New Mexican politics. He reportedly donated $50,000 for Richardson's 2002
+campaign and another $50,000 to Richardson's re-election campaign this year, $15,000 to attorney genera
+andidate Gary King, $10,000 to state land commissioner candidate Jim Baca and $2,000 to Santa Fe
+ounty Sheriff Greg Solano. King says he'll dump the Epstein tainted money, Baca said he is discussing
+ith his campaign manager and Sheriff Solano says he has already spent the money and doesn't have ar
+EFTA00067275
+
+A note to King and Baca-you might think twice about actually giving the money back to
+Epstein. As we noted before, who knows what he's going to use it for. Better to follow Richardson's
+example and we're not saying he picked up the idea from DealBreaker but we secretly suspect he did-and
+give the money to charity.
+Governor to dump cash from billionaire [The New Mexican]
+Posted by John Carney at 01:25 PM on August 16, 2006 | Permalink | Comments (3) | TrackBacks (0)
+FBI Mulling Jeffrey Epstein Investigation
+Jeffrey Epstein may be headed for more legal trouble. The New York Post's Dan Mangan is reporting that
+touched them with vibrators. It is also alleged that in at least one incident he paid a girl $1,000 after he
+forcibly penetrated her. Epstein is also alleged to have employed a "sex slave" he allegedly claimed to have
+purchased from her family in eastern Europe to have sex with one of his untrained masseuses while he
+watched.
+Palm Beach police, frustrated with what they reportedly view as a lack of dedication on the part of local
+prosecutors, have turned information over to the FBI. Mangan breaks news in his story by getting word
+from an FBI investigator that the feds are indeed following up on the case.
+Mystery Mogul's Teen-Sex Secret Bared in Probe [New York Post]
+More of DealBreaker's Jeffrey Epstein Coverage [Archives]
+Posted by John Carney at 09:49 AM on August 16, 2006 | Permalink | Comments (O) | TrackBacks (O)
+Jeffrey Epstein: The Story So Far
+This morning's Palm Beach Post carries a lengthy article on Jeffrey Epstein. It mostly tracks what you've
+already read here or elsewhere but is worth reading if you haven't followed all the details. Among the
+highlights:
+Background.
+• Jeffrey Epstein's early career at Dalton and Bear Stearns.
+• His earlier disputes with former business partners and Citigroup.
+• Rumors that he left Bear Stearns under an SEC inquiry cloud.
+• Also rumored to have been a spook of some sort.
+• Mentored by Steven Hoffenberg "now serving a prison term after "bilking investors out of more than $450
+million in one of the largest Ponzi schemes in American history.'
+• His real estate: private island, huge townhouse in Manhattan, gigantic in new Mexico and a alleged
+teenage petting zoo mansion in Palm Beach.
+• Powerful friends: top scientists, former Harvard president Larry Summers, Daily News publisher Mort
+Zuckerman and Bill Clinton.
+• Thought to have 15 clients but only one is known-the Wexner family, founders of The Limited clothing
+stores.
+EFTA00067276
+
+Women.
+• Long linked to media mogul Robert Maxwell's daughter Ghislaine Maxwell.
+• Said to have also dated a former Miss Sweden and a Romanian model.
+The Case.
+• Investigation began after a mother heard her daughter discussing trips to Epstein's place and contacted
+police
+• Private investigators working for Epstein contacted witnesses during the investigation.
+• Disputes arose between prosecutors and police.
+• An early plea bargain which would have kept Epstein out of jail fell apart
+• Alan Dershowitz flew to Palm Beach to paint the girls making the allegations against Epstein as lying
+thieving, drug and alcohol abusing and unreliable.
+• The "Heidi Fleiss" of Palm Beach is alleged to have brought six girls between ages 14 and 18 to Epstein's
+house for massages.
+While admitting that Epstein had girls over to administer massages, Epstein's camp maintains he is innocent
+of any criminal wrong-doing. One of his lawyers even insists Epstein will emerge from the case with his
+reputation untarnished.
+Jeffrey Epstein craved big homes, elite friends - and, investigators say, underage girls [Palm Beach Post]
+Posted by John Carney at 10:02 AM on August 14, 2006 | Permalink | Comments (6) | TrackBacks (0)
+Clearly, This Is When A Private Plane Comes In Handy
+Jossip-which along with DealBreaker, Gawker and the Palm Beach Post is just about the only media outlet
+covering the Jeffrey Epstein story—notes that terrorists have totally screwed any plans Epstein might have
+had to fly commercial this weekend. No batteries or liquids allowed on planes?
+Which more or less means Jeffrey Epstein's weekend is totally fucked. How can he enjoy a night of petting
+zoo on his private jet without massage oils and working vibrators? Talk about inconvenience.
+Ah. Poor innocent Jossip. Epstein doesn't fly commercial and you can bring whatever you want onto your
+private jet. This is what private planes are for. So even terrorists can't fuck with your travel plans.
+[Note: As we've said before, everything seems dirty when it is about Epstein, even perfectly ordinary
+hrases like "comes in handy." Even "Palm Beach Post" is kind of icky and we're not sure why. We're sorry
+hat's not out fault. It's either Eostein's or those Iving little drua addict sluts
+[Another note: Shouldn't we have gone with some version of "If Epstein can't travel with lube and vibrators,
+the terrorists win?*-Ed. Uhm, are we still using that joke? If that hasn't jumped the shark, I just threw up
+in my mouth a little. Very funny. If we can still do these '—Ed' jokes, I think we can still do the terrorists win
+jokes.—Ed. I hope meta is still funny.]
+Terrorists Totally Ruin Jeffrey Epstein's Weekend [Jossip]
+Posted by John Carney at 04:22 PM on August 10, 2006 | Permalink | Comments (2) | TrackBacks (0)
+Epstein Got Off Too Easy, Palm Beach Post Says
+EFTA00067277
+
+Why didn't prosecutors charge Jeffrey Epstein with more serious crimes? The police reports
+include allegations of sexually-tinged massages with girls as young as 14, human trafficking and something
+that seems a lot like rape to us. But he gets slapped with nothing more than a single solicitation charge
+after prosecutors referred the case to a grand jury.
+So what happened? It seems that Epstein's high-powered legal team crafted an ingenious and original
+"drunk, drug-addled lying sluts" defense and intimidated the prosecutors out of bringing charges. Here's
+how the Palm Beach Post puts it:
+The girls, Mr. Dershowitz told prosecutors, had written on myspace.com about smoking marijuana and
+drinking alcohol. But if the girls have a credibility problem, what about Jeffrey Epstein? Mr. Goldberger, told
+The Post: "Mr. Epstein absolutely insisted anybody who came to his house be over the age of 18. How he
+verified that, I don't know." And prosecutors took him at his word?
+A more charitable way to look at the situation is that prosecutors may have been hesitant to put teenage
+girls on the stand knowing that Epstein's lawyers would likely turn his trial into a forum for attacks on their
+characters, sexual history and allegations of drug use and prostitution.
+Massaging the system [Palm Beach Post]
+Posted by John Carney at 01:15 PM on August 10, 2006 | Permalink | Comments (O) | TrackBacks (0)
+Jeffrey Epstein Fights Back: "These women are liars."
+leffrey Epstein has launched an army of lawyers and publicists to clear his name and smear the girls who
+lave accused him of sexual improprieties and solicitation, the Palm Beach Post reports this morning. Here's
+a quick look at the line coming out from Epstein's camp.
+In Epstein's army: attorneys Jack Goldberger, Alan Dershowitz and. Roy Black. New York publicist Dan
+Klores and an unnamed Los Angeles publicist.
+The spin: these girls are liars, thieves and drug-users. The Palm Beach police are on a childish vendetta.
+What Epstein's camp admits: Epstein did have young women over to his house to administer massages
+There is no explanation for why he was paying untrained girls upwards of $200 for massages
+What they're denying: That Epstein had any knowledge the girls were underage or that Epstein had sex with
+any underage girls.
+There's a gap between what has been alleged and what is being denied, and that gap might be informative.
+Even if Epstein didn't 'have sex' with the girls, did he have them strip and did he masturbate while they
+massaged him?
+Ugh. Suddenly we're back in Clinton-Lewinsky territory, trying to guess at what the meaning of 'sex' is.
+Epstein camp calls female accusers liars [Palm Beach Post]
+Posted by John Carney at 10:01 AM on August 08, 2006 | Permalink | Comments (3) | TrackBacks (0)
+EFTA00067278
+
+Joe Francis and The Girls Gone Wild Theory of Jeff
+Epstein
+Joe Francis, the man who built an empire on young girls exposing themselves for his "Girls Gone Wild"
+videos, offers a completely self-serving theory about entrepreneurialism and sex to a writer for the LA Times
+magazine.
+"Sex sells everything," he says.
+"It drives every buying decision ... I hate to get too deep and philosophical
+here, but only the guys with the greatest sexual appetites are the ones who are the most driven and most
+successful."
+This was crap when we first heard it as the feminist theory of capitalism that successful businessmen were
+imply acting out their rape fantasies on the economy. And it's truly disgusting crap coming from anyon
+who does the things Joe Francis is alleged to have done in the article-assaulting a reporter, getting
+teenager drunk and more-or-less raping her, and generally being an ass. No idea about how much of this
+story is accurate but if even if it's dimes-from-dollars, it's awful stuff.
+We couldn't help but remember that Jeffrey Epstein is reportedly interested in alternative theories of
+evolutionary psychology. Maybe he and Joe should get in touch with each other.
+'Baby, Give Me a Kiss' [L.A. Times Magazine]
+Posted by John Carney at 12:01 PM on August 07, 2006 | Permalink | Comments (2) | TrackBacks (Q)
+Today in Jeffrey Epstein: He Thinks You Are An Insect.
+We feel awful for letting you down yesterday. An entire day without a post on Jeffrey Epstein. No one
+should have to tolerate that kind of neglect. Unless, you know, they get their news from the New York
+Times.
+A blogger at Verum Serum asks whether Epstein's interest in alternatives to evolutionary psychology and the
+work of E.O. Wilson might offer an insight into his alleged behavor:
+My question about all this is simple. Is there a connection between the two threads in Jeffrey Epstein's life?
+Between his scientific beliefs about human nature and his behavior toward women (and girls)? Put another
+vay, when you see people as something akin to insects, does that alter your behavior toward them? Whe
+rou see human trust and kindness as merely adaptive behaviors, does that render you less trustworthy
+We'll answer all four questions. Yes. Yes. Yes. No.
+Patron of Evolutionary Science Kept Sex Slave [Verum Serum]
+Posted by John Carney at 02:56 PM on August 04, 2006 | Permalink | Comments (4) | TrackBacks (0)
+Pretty Much Most of the News That's Fit to Print So Long As It's
+Not About Jeffrey Epstein
+EFTA00067279
+
+It's three o'clock already and we haven't even mentioned Jeffrey Epstein. We'd feel like we
+were neglecting our journalistic duties but that might make the nice folks at New York Times feel lazy.
+They've never once mentioned Jeffrey Epstein since the sex scandal broke, as Jossip points out.
+So, fine. We are going to be obsessive ...And we are going to point out - yet again - that a very rich and
+powerful man was accused of some really terrible things ... and the New York Times has officially let a week
+go by without a single mention of his name.
+Come on, Jossip. That's unfair. We're sure they mean to get around to the story. It's just so hard to find
+room in the paper when it is so packed with hard news.
+Jeffrey Epstein Still Immune From New York Times Coverage: Day Z Dossip]
+Posted by John Carney at 03:00 PM on August 02, 2006 | Permalink | Comments (Q) | TrackBacks (0)
+Jeffrey Epstein and Those Nobel Prize Winning Orgiasts
+As we mentioned earlier today, over on the very, very much Not Safe For Work Moneyshot blog, the
+pseudonymous Shermon McCoy claims that he's been at Jeffrey Epstein parties in which Nobel prize winners
+and various wealthy folks were all surrounded by young, "nude eastern european girls, frolicking with them,
+and then proceeding into one big orgy party." Uhm, okay. So who were these Nobel prize winners? So far
+we haven't been able to confirm anything.
+But we have uncovered published reports about a boondoggle orgy physics symposium in St. Thomas that
+Epstein organized, which was attended by Nobel prize winners Gerardus't Hooft, David Gross and Frank
+Wilczek, and physicist Stephen Hawking. We don't want to suggest that Hawking got all freaky with
+Epstein's alleged sex-slave. Or that anyone did anything wrong or unbecoming. Or that any of these physics
+guys have ever had sex with anyone, for that matter.
+But the story does suggest it wasn't all equations and string theory.
+Delegates from the University of the Virgin Islands and Antilles School also attended the reception, where a
+few free spirited physicists braved the dance floor.
+"There is no agenda except fun and physics, and that's fun with a capital 'F, Epstein said.
+Before the Epstein story broke we might have read that with a straight face. Now we cannot help but
+wonder exactly who these "delegates" were. Were they professors? Or students? And why do we think that
+the capital "F" wasn't just for fun?
+That's probably completely unfair. But like we said before. In light of the allegations, everything we read
+about Epstein seems creepy.
+Physicists Debate Gravity at St. Thomas Symposium [St. Thomas Source]
+Posted by John Carney at 06:05 PM on August 01, 2006 | Permalink | Comments (9) | TrackBacks (0)
+Epstein Update: Nobel Prize Wide Shut
+EFTA00067280
+
+STANLEY KUBRICK COLLECTION
+According to the anonymous author of TheMoneyShot, Shermon McCoy (har), our
+flood-the-zone coverage of Jeffrey Epstein's alleged personal pubescent predilictions
+is entirely based on one thing: we're jealous!
+All these people are, I suspect, just slightly jealous that they were never invited to a
+Epstein party.** Being one of those privy to just such an event- barely-legal (I hope!)
+Russian girls and all- I can say that I understand why. There really is nothing else I
+have ever experienced quite like it. Nobel prize winners, a bunch of people intimately
+involved in ... cough! cough! Numerix cough! and cough! Prediction Company cough!
+cough!, Jeff himself, and some rich people who really don't matter- all surrounded by
+EYES WIDE SHUT
+18-, 19-, and 20- (again, I hope!) year old nude eastern european girls, frolicking
+with them, and then proceeding into one big orgy party. It was really strikingly
+similar to Eyes Wide Shut. Without the costumes, that is.
+Well, Sherman, we'll admit that we're jealous of your blog idea. Porn and finance! At the same time! Two
+great tastes that go great together. Why didn't we think of that?***
+it more importantly, we're deeply curious about which Nobel prize winners have been known to froli
+ans tweed with nude Eastern European girls. And we're curious about the rich people who don't matter a
+well. C'mon! Give us a hint!
+** Well, that's a little presumptuous, Sherman.
+*** No, seriously. Why didn't we think of that? Minkin? Carney?
+Dealbreaker and More Jeffrey Epstein (NSFW) [TheMoneyShot]
+Posted by Elizabeth Spiers at 12:00 PM on August 01, 2006 | Permalink | Comments (12) | TrackBacks (0)
+The Perfect Storm, DealBreaker Style
+We've been spending some time trying to clear away the murk and shine some light into the shadows of
+Jeffrey Epstein's financial dealings in an effort to provide some, uhm, actual financial reporting related to
+the sex candal encircling the mysterious money manager. There's not much that is publicly available but
+we're still digging.
+What we have discovered, however, is a brief document amending a credit agreement for RELIANT
+PHARMACEUTICALS, INC. The amendment replaces the administrative agent for the credit. But what caught
+our eye was the confluence of three DealBreaker subjects all in the same documents.
+The signature pages include lines for Morgan Stanley CEO John Mack, who is scheduled to appear before
+obsession, Hank Paulson).
+Now this is no doubt just a coincidence, and not really a conspiracy to make our heads explode. We should
+probably just take a deep breath and then post a Venn Diagram illustrating the connections but our
+diagramist is in meetings off-site.
+One additional thought: this is probably the last time you'll see Epstein's name coupled with the words
+"trust" and "children" any time in the near future.
+EFTA00067281
+
+Reliant Consent, waiver and amendment [SEC]
+Posted by John Carney at 05:01 PM on July 31, 2006 | Permalink | Comments (0) |
+TrackBacks (0)
+Jeffrey Epstein's Been Around Young Girls Before
+Does the fact that Jeffrey Epstein taught high school math and physics at Dalton for three
+years creep anyone else out? Unless you've been depending on the New York Times for your
+news, by now you know that Jeffrey Epstein has been charged with felony solicitation of
+osutton ratner than even more serious charges of molestation and sex with minors. But the facts allege
+the police affidavit released on the Smoking Gun clearly spell out a taste for getting voung. hiah scho
+age girls to co-operate in some pretty raunchy scenarios. This raises the question: how long has this been
+Did you go to Dalton in the mid-seventies? Epstein taught there from 1973 through 1975, when he left to
+take a job at Bear Stearns. We'd love to hear from you if you remember Epstein from those years, whatever
+your impressions-good, bad, ugly or totally perverse. Unless otherwise indicated, we'll keep your
+comments completely anonymous. Send your comments to tips(at)dealbreaker(dot)com.
+[* Editors Note: We know, we know. It may not have gone on at all. Everyone is innocent until proven
+guilty. God loves all his little creatures. The allegations and charges are serious, though, and we don't think
+it's too early to start asking these questions.]
+Posted by John Carney at 03:39 PM on July 31, 2006 | Permalink | Comments (2) | TrackBacks (0)
+On further reflection, maybe giving money back to Jeffrey
+Epstein isn't such a good plan
+Why are Mark Green and Eliot Spitzer handing $60,000.00 over to alleged money manager cum massage
+masturbator Jeffrey Epstein? It's pretty standard procedure these days for politicians to send back
+contributions from donors accused of crime or mired in scandal, and we quess allegations of soliciting
+prostitution, paying for naked massages from teenagers, human trafficking and all around pervy weirdness
+qualify. But is sending the check back really the right move here? Wouldn't it be better to donate the money
+to a worthy cause, such a home for sexually abused children? Why should Epstein be enriched by these
+allegations?
+Let's put it this way. By sending back Epstein's $10,000 donation, Attorney General candidate Green just
+bought Epstein 50 sessions with local highshool girls at $200 a pop.
+Dirty donor to get 10G back: Green [Daily News]
+Posted by John Carney at 11:33 AM on July 31, 2006 | Permalink | Comments (O) | TrackBacks (0)
+Meet
+Jeffrey Epstein's Other Girl
+EFTA00067282
+
+We're told that the dirty little nymph in this picture is
+bersonal assistant of Jeffrey Epstein who is alleged to have arranged
+many of her boss's alleged naked massage sessions with teenage girls.
+The woman in this picture bears a striking resemblance to confirmed
+including one where she is pictured palling around
+with Epstein's alleged eastern European sex-slave
+I could not be reached for comment.
+More pictures of L
+(probably) on the link below.
+? [Strobe Models]
+Posted by John Carney at 10:47 AM on July 31, 2006 | Permalink |
+Comments (1) | TrackBacks (O)
+Another Jeffrey Epstein Victim? Naughty
+May Be A Victim of International
+Sex Slave Trade
+was written on the assumption that unlike the young girls Jeffrey
+Epstein is alleged to have paid to strip and massaged him while he pawed at them and masturbated into a
+towel, the eastern european blonde was a different kind of participant. Older, more sophisticated, at least a
+little lezzy and wearing stap-on dildos. That sort of thing. Just the sort of woman you'd imagine an evil
+villain would keep as his mistress.
+EFTA00067283
+
+As it turns out, that sort of woman probably only exists in fiction. Gawker is now reporting that according to
+a previously unpublished Palm Beach police document, Epstein bragged that he purchased
+family in Yugoslavia, and that she was his sex slave. So she may be another victim of Epstein's alleged sex-
+and girls-for-money racket.
+The weird thing is that
+seems to have at least
+his alleged sex slave as a real estate agent? Isn't being a sex slave at least a full time job?
+Did Epstein set up
+[Oh. And yeah. Alleged. Alleged. Allegedallegedallegedallegedtoinfinity. Epstein hasn't been found guilty of
+anything and it's up to the government to prove its case against him.]
+Exclusive: Jeffrey Epstein's Sex Slave [Gawker]
+Posted by John Carney at 04:38 PM on July 28, 2006 | Permalink | Comments (2) | TrackBacks (0)
+Meet |
+Epstein Scandal
+,, Star Girl of the Raunchiest Part of
+Without a doubt, the absolutely raunchiest part of the Epstein
+affadavit stars a mysterious young woman named "
+•" Lesbian strap-on raunchiness, ending in
+something that sounds to us a little bit like rape. We get all
+the details but no explanation of who |
+• is or what
+her relationship with Epstein was. She's not one of his high
+school victims, and doesn't seem to have talked to the police.
+But it somehow seems fitting that this mysterious money
+manager to the billionaires would have an unknown Czech sex
+puppet lying around somewhere.
+where
+(far left) is palling around with Epstein's pimp assistant
+(right).
+Here she looks very respectable. Not at all like the "large
+rubber penis" wielding girl we know from the affadavit. Surely
+there's a more representative photo.
+Of course there is. After the jump, check out
+| looking a little more, uhm, severe, sexy and ready to get
+it on. And we'll throw in the raunchy portion of the affadavit below for your, uhm, reading pleasure.
+Continue reading "Meet
+Star Girl of the Raunchiest Part of Epstein Scandal"»
+Posted by John Carney at 11:11 AM on July 28, 2006 | Permalink | Comments (8) | TrackBacks (O)
+In Retrospect, Everything Ever Said About Jeffrey Epstein
+Seems Creepy
+EFTA00067284
+
+If you spend even a few moments reading the probable cause affidavit detailing mysterious money manager
+Jeffrey Epstein's alleged penchant for paying naked teenagers to massage him while he, uhm, whacked-off,
+everything else you read about him starts to seem creepy too.
+There's the now famous line in New York magazine's profile. You know, the one where Donald Trump is
+quoted as saying about Epstein, "He's a lot of fun to be with. It is even said that he likes beautiful women
+as much as I do, and many of them are on the younger side. No doubt about it -- Jeffrey enjoys his social
+life. " Wow. That's awkward now.
+But it doesn't stop there. One thing that's clear from the affidavit is that Epstein's assistant
+alleged to have played a central role in procuring the high school girls who rubbed him down for a couple of
+hundred dollars a pop. She's said to have called the girls when Epstein was in town, got them situated in his
+bedroom and even passed around refreshing beverages for the girls to enjoy.
+As it turns out, one of the rare journalism interviews Epstein has given involved his executive assistants. The
+New York Times story "Working for Top Bosses on Wall St. Has Its Perks" (cough, pimping, cough) is now
+hidden safely from prying eyes behind the Times Select firewall but DealBreaker has boldy shelled out the
+Abe Lincoln to bring the story to our readers. After the jump, we bring you the excerpts with emphasis and
+nasty asides added.
+Continue reading "In Retrospect, Everything Ever Said About Jeffrey Epstein Seems Creepy"»
+Posted by John Carney at 09:33 AM on July 28, 2006 | Permalink | Comments (4) | TrackBacks (0)
+© 2006 - Dealbreaker.com - 11 Beach St, 3rd Floor, New York, NY 10013 | Privacy Policy | Terms of Service
+EFTA00067285

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vision-joined/ds9-unparsed-01/8ffe386307e5ff0adf5d5bb0cc80deefb0ded07a9f7ab11651fb5f31dc325e8c.md

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+U.S. Department of Justice
+United States Attorney
+Southern District of New York
+The Silvio J. Mollo Building
+One Saint Andrew's Plaza
+New York, New York: 10007
+March 29, 2021
+BY ECE
+The Honorable Alison J. Nathan
+United States District Judge
+Southern District of New York
+40 Foley Square
+New York, New York 10007
+Re:
+United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)
+Dear Judge Nathan:
+The Government writes to notify the Court that today, a Grand Jury sitting in Manhattan
+returned a superseding indictment in the above-captioned case (the "S2 Indictment").' The
+Government respectfully submits this letter (1) to identify the differences between the charges
+contained in the S2 Indictment and the charges contained in the prior indictment, S1 20 Cr. 330
+(AJN) (the "S1 Indictment"); (2) to address the impact, if any, of the S2 Indictment on the status
+of discovery and other disclosures; and (3) to address the impact of the S2 Indictment on the
+currently pending motions.
+' The Government noted in its February 26, 2021 Omnibus Memorandum of Law in Opposition
+to the Defendant's Pretrial Motions that its investigation remained ongoing and that the
+Government would seek a superseding indictment no later than three months prior to trial. At this
+juncture, while the Government's investigation is still ongoing, if trial remains set for July 12,
+2021 as scheduled, then the Government does not intend to seek any further indictments in this
+case. To the extent the Government uncovers additional evidence that it may seek to introduce at
+trial, it will promptly disclose such evidence to the defense as either Rule 16 or Jencks Act material.
+Additionally, the Government remains cognizant that its Brady obligations remain ongoing and
+will promptly disclose any exculpatory evidence of which it becomes aware.
+EFTA00080582
+
+Page 2
+I.
+Comparison of the S1 Indictment and the S2 Indictment
+Count One of the S2 Indictment charges the defendant with participating in a conspiracy
+to entice minors to travel, in violation of 18 U.S.C. § 371, which is the same statutory violation as
+Count One of the S1 Indictment. Whereas Count One of the S1 Indictment alleged that this
+conspiracy lasted through in or about 1997, Count One of the S2 Indictment alleges that the
+conspiracy continued through in or about 2004 and specifically identifies a fourth victim, Minor
+Victim-4, who was a vietim of this conspiracy between approximately 2001 and 2004.
+Count Two of the S2 Indictment remains identical to Count Two of the S1 Indictment and
+is unchanged.
+Count Three of the S2 Indictment charges the defendant with participating in a conspiracy
+to transport minors, in violation of 18 U.S.C. § 371, which is the same statutory violation as Count
+Three of the S1 Indictment. Whereas Count Three of the S1 Indictment alleged that this conspiracy
+lasted through in or about 1997, Count Three of the S2 Indictment alleges that the conspiracy
+continued through in or about 2004 and specifically identifies a fourth victim, Minor Victim-4,
+who was a victim of this conspiracy between approximately 2001 and 2004.
+Count Four of the S2 Indictment remains identical to Count Four of the S1 Indictment and
+is unchanged.
+Count Five of the S2 Indictment adds a new charge against the defendant. In particular,
+Count Five alleges that the defendant participated in a sex trafficking conspiracy between
+approximately 2001 and 2004, in violation of 18 U.S.C. § 371. The S2 Indictment specifically
+identifies Minor Vietim-4 as a victim of this conspiracy.
+EFTA00080583
+
+Page 3
+Count Six of the S2 Indictment adds another new charge against the defendant. In
+particular, Count Six alleges that the defendant participated in the sex trafficking of a minor, and
+aided and abetted the same, in violation of 18 U.S.C. §§ 1591 and 2. The S2 Indictment
+specifically identifies Minor Victim-4 as the victim of this count.
+Count Seven of the S2 Indictment is identical to Count Five of the S1 Indictment and is
+otherwise unchanged.
+Count Eight of the S2 Indictment is identical to Count Six of the S1 Indictment and is
+otherwise unchanged.
+Il.
+Disclosures
+The Government has already produced to the defense all material that constitutes Rule 16
+discovery related to the new allegations and charges contained in the S2 Indictment. In particular,
+the Government has from the outset approached its Rule 16 productions in this case as though the
+allegations
+covered a broader time period through at least 2005, rather than limiting those
+productions to the time period alleged in the S1 Indictment (1994 to 1997). As a result, the
+Government has already produced to the defense all Rule 16 material relevant to the S2 Indictment
+of which it is aware in the Prosecution Team's possession. These Rule 16 materials included
+productions from the files of the Federal Bureau of Investigation ("FBI") Palm Beach Resident
+Agency (the "FBI Florida Office"), the FBI New York Office, and the U.S. Attorney's Office for
+the Southern District of New York.
+To assist the defense in preparing for trial on the new allegations contained in the S2
+Indictment, today the Government provided the defense with Minor Victim-4's month and year of
+birth. Additionally, in order to aid the defense in its trial preparation and review of the discovery,
+EFTA00080584
+
+Page 4
+today the Government provided the defense with a list of Bates ranges within the discovery
+materials produced to date that are particularly relevant to Minor Victim-4. Although that list is
+not exhaustive and does not include every document that may be relevant to Minor Vietim-4, it
+identifies key pieces of evidence regarding this victim.
+Additionally, in order to ensure that the defense has adequate time to prepare for trial, the
+Government intends to begin its production to the defense of non-testifying witness statements by
+April 12, 2021, approximately three months in advance of trial. This production will include the
+statements of more than 250 witnesses related to the investigation of Jeffrey Epstein and his
+associates in the Government's possession whom the Government does not currently expect to call
+to testify at trial. The Government is continuing to review its files for witness statements and will
+produce any additional non-testifying witness statements that come to light on a rolling basis as
+promptly as possible in advance of trial.
+Finally, given the expanded charges in the S2 Indictment, the Government is prepared to
+produce Jencks Act and Giglio material for witnesses it expects to call at trial six weeks, rather
+than four weeks, in advance of trial. These productions, together with the guidance provided to
+the defense today regarding discovery relating to Minor Victim-4, should provide ample time for
+the defense to prepare for trial and proceed as scheduled on July 12, 2021.
+II.
+Motions
+In light of the new allegations and charges contained in the S2 Indictment, the Government
+will meet and confer with defense counsel to discuss whether defense counsel wishes to bring
+additional motions (or supplement existing motions) based on the S2 Indictment and, if so, to
+discuss a proposed schedule for any additional briefing. Although the S2 Indictment should have
+EFTA00080585
+
+Page 5
+no impact on several of the defendant's motions, such as the motions to suppress (Motion 3 and
+Motion 11), the motion to dismiss the perjury counts (Motion 4), and the motion to strike
+allegations regarding Minor Victim-3 as surplusage (Motion 6), the Government does not
+anticipate objecting to any defense request to file supplemental briefing regarding any issue that is
+implicated by the S2 Indictment. The Government also notes that the S2 Indictment was returned
+by a grand jury sitting in Manhattan, rendering moot the defendant's motion to dismiss based on
+the use of a grand jury sitting in White Plains (Motion 9).
+Respectfully submitted,
+AUDREY STRAUSS
+United States Attorney
+by:
+/s/
+Assistant United States Attorneys
+CC:
+Counsel of Record (by ECF)
+EFTA00080586

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vision-joined/ds9-unparsed-01/9001a6869959431ad09922e2c9f13549146c9a42be581b1b4d18565de3cbf0b0.md

@@ -0,0 +1,24 @@
+From: "I
+To: "l
+Ce: "l
+(USANYS) 3" <
+(USANYS)" 4
+D 1"<
+Subject: Re:
+Date: Sat, 10 Aug 2019 13:33:51 +0000
+Glad it went on at least.
+We can bring a civil forfeiture against the properties IF we're within statute, which we may not be. We'll have to
+look at it, but we've got some time, since I'm pretty sure no one's going to want to have that be was our
+immediate reaction to his suicide. We can't pursue any kind of general money judgment against the estate - there
+we're out of luck.
+Sent from my iPhone
+> On Aug 10, 2019, at 9:27 AM,
+• (USANYS) <
+P wrote:
+> Had my surgery. Went so so. Just got home. Will know more in about a week.
+>
+>
+> In separate news and not to be crass but Epstein! Wow. Can we still pursue forfeiture against the estate? I
+believe he has a living brother.
+> Sent from my iPhone
+EFTA00065264

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@@ -0,0 +1,182 @@
+From:
+To: "
+(USANYS)" <
+(USANYS)" <
+Cc: "
+(USANYS) [Contractor]" <
+Subject: RE: NYLJ
+Date: Thu, 14 Nov 2019 16:08:12 +0000
+(USANYS)"
+Also, NYT reporting on a possible victims fund:
+Jeffrey Epstein's Estate May Set Up a Program to Pay Accusers
+A proposal for a "claims resolution program" was referred to in a court filing by a lawyer for a woman who accused the
+financier of sexual abuse. Not all the plaintiffs' lawyers are on board.
+By Matthew Goldstein
+Nov. 13, 2019
+Lawyers for Jeffrey Epstein's estate are considering setting up a program to resolve claims filed by women
+who say they were abused by the financier, who killed himself in August while facing federal sex
+trafficking charges.
+The plan was disclosed in a court filing on Tuesday by a lawyer for one of Mr. Epstein's accusers, who is
+suing the estate in federal court in Manhattan. The filing said lawyers for Mr. Epstein's estate had
+informed plaintiffs that they were planning to disclose details of a "claims resolution program" to a court
+in the United States Virgin Islands, where the mysteriously wealthy Mr. Epstein had his will filed shortly
+before his death.
+The estate has retained Kenneth R. Feinberg, the noted lawyer who specializes in compensating victims, to
+set up the program, his team confirmed late Wednesday. His associates Camille Biros and Jordana
+Feldman have also been tapped, and Ms. Feldman will carry out the plan once it is set up and if it meets
+court approval. Ms. Biros has been an architect of programs to provide restitution to victims of the
+Catholic Church abuse scandal. Ms. Feldman most recently played a critical role in overseeing the
+administration of the September 11 Victims Compensation Fund.
+But the proposal from lawyers for the estate, which is valued at about $577 million, was facing resistance
+earlier in the day.
+Bradley Edwards, the lawyer for the accuser, said in the court filing that his client "does not believe that
+the use of any alternative dispute resolution should stay or modify the course of litigation in this matter."
+A lawyer for the estate wrote to one accuser's lawyer and described the proposed program as "voluntary,"
+according to emails reviewed by The New York Times. Even so, the accuser's lawyer, Roberta Kaplan,
+objected to the plan's being put together without consulting with the accusers and their lawyers.
+"Settlement, after all, is a two-way street," Ms. Kaplan said in an emailed response, which was also sent to
+lawyers for other accusers. She said it was "astonishing" that the lawyers for Mr. Epstein's estate planned
+to go to court in the Virgin Islands without first discussing the plan.
+"In fact, it feels very much like a continuation of his crimes and abuse after his death," she wrote.
+The emails were later included in a public court filing on Wednesday afternoon.
+EFTA00040555
+
+David Brodie, another accuser's lawyer, said that he was "cautiously optimistic" about the possible
+resolution program, but that there were many questions about how claims would be handled.
+"These women have already endured horrific abuse at the hands of Jeffrey Epstein and have waited many
+years for justice," he said. "To turn their personal experiences over to one person selected by Jeffrey
+Epstein's estate to make a binding decision (which may not be disputed) could be a process that may
+exacerbate the victimization of these brave women."
+Bennet Moskowitz, the lawyer hired by Mr. Epstein's estate to handle lawsuits by the accusers, did not
+respond to requests for comment on the emails or the proposed resolution program.
+The executors of Mr. Epstein's estate, Darren Indyke and Richard Kahn, also did not respond to a request
+for comment. Mr. Indyke was Mr. Epstein's longtime lawyer in New York, and Mr. Kahn was an
+accountant for some of his companies.
+In the weeks since Mr. Epstein's death, lawsuits against the estate have been piling up.
+On Tuesday, three new lawsuits were filed in Manhattan federal court by Mr. Epstein's accusers, including
+separate lawsuits filed by two sisters
+Their lawyer, David Boies, said he anticipated filing lawsuits on behalf of at least one other woman, and
+called a settlement program "a positive step" toward resolving the claims. "But it is only the first step," he
+Until last month, Mr. Boies's firm represented one of Mr. Epstein's most outspoken accusers,
+in a defamation lawsuit against the former Harvard law professor Alan Dershowitz. A
+federal judge disqualified the firm, saying its lawyers might have to appear as witnesses in the litigation.
+Some accusers are taking advantage of a new law in New York that allows child victims of sexual abuse to
+file claims for damages many years later. Many of Mr. Epstein's accusers said they were abused more than
+a decade ago.
+New York law also permits crime victims to file lawsuits seeking damages within a year of the termination
+of a criminal case against the defendant. The clock on such claims started on Aug. 29, when federal
+prosecutors dismissed a sex-trafficking indictment against Mr. Epstein after his suicide at the Manhattan
+Correctional Center.
+If a claims resolution program is formed, it's possible that dozens of women could seek monetary
+damages. When Mr. Epstein pleaded guilty in 2008 in Florida state court to a charge of soliciting
+prostitution from a minor, it was estimated in court filings that he had engaged in sexual activity with at
+least 30 underage girls.
+From:
+To:
+Cc:
+Subject: NYU
+(USANYS)
+Sent: Thursday, November 14, 2019 11:05 AM
+(USANYS) <
+(USANYS) [Contractor] y
+(USANYS) <
+EFTA00040556
+
+Boies Schiller Sues Jeffrey
+Epstein Estate on Behalf of
+3 Sexual Abuse Accusers
+The lawsuits, filed in U.S. District Court for the Southern District of New
+York, include claims for battery and intentional infliction of emotional
+distress by plaintiffs who said they met Epstein and his companion,
+Ghislaine Maxwell, between 1995 and 2002.
+By Tom McParland | November 12, 2019 at 03:21 PM
+Boies Schiller Flexner attorneys on Tuesday sued the estate of Jeffrey Epstein on behalf of
+at least three women who said they were sexually abused by the deceased financier after
+being recruited into his alleged sex-trafficking network in New York.
+The lawsuits, filed in U.S. District Court for the Southern District of New York, include
+claims for battery and intentional infliction of emotional distress by plaintiffs who said they
+met Epstein and his companion, Ghislaine Maxwell, between 1995 and 2002.
+Two of the women,
+and
+were the subjects of New York Times
+reporting in August, which identified the two sisters as the first to report abusive behavior
+by Epstein at his Manhattan townhouse. Though the FBI took up an investigation, the
+Times reported, a widely criticized 2008 plea deal eventually derailed any federal
+prosecution.
+According to
+complaint, Epstein had hired her to purchase art for him,
+though her job responsibilities soon shifted to "focus on monitoring and keeping records of
+who entered Epstein's New York mansion." She said that Epstein took interest in personal
+details about her family, and upon hearing that she had a younger sister, arraigned to have
+-year-ola
+flown to New York.
+While there
+said, Epstein groped |
+in a movie theater and eventually
+flew the girl to his New Mexico ranch, where he assaulted her. In her own lawsuit
+EFTA00040557
+
+said that Maxwell, a British socialite who has been accused of procuring young
+women and underage girls for Epstein, pressured her to have physical contact with Epstein
+and that both adults participated in the abuse, under the guise of a massage.
+Both of the
+and Sigrid McCawley of Boies Schiller.
+are represented in the litigation by David Boies, Joshua Schiller
+claimed in her filing that "Maxwell was regularly bringing school-aged girls to
+the mansion" in New York, and that they were always escorted upstairs.
+who
+was years old at the time, said she was told that the girls were interviewing for modeling
+positions with lingerie retailer Victoria's Secret and was unaware of Epstein's sex-trafficking
+conspiracy at the time.
+The complaint included a reference to former Harvard law professor Alan Dershowitz, who
+she said visited the mansion "on a number of occasions" and "would go upstairs at the
+same time the young girls were there."
+While the filing did not contain any explicit allegations of wrongdoing by Dershowitz, it did
+signal the latest salvo in an ongoing feud between the professor and Boies Schiller, which
+has represented Epstein accusers in a range of civil litigation.
+Until recently, Boies and McCawley represented
+who claimed that
+Dershowitz had defamed her through his strong denials of forced sex. Dershowitz has filed
+counterclaims agains
+and last week Boies sued Dershowitz, claiming that he had
+falsely accused him of extortion.
+Dershowitz has repeatedly and forcefully denied allegations that he had sex with anyone in
+Epstein's orbit. On Tuesday he said
+account that she had seen him at
+Epstein's mansion in 1995 was "categorically" false.
+According to Dershowitz, he never visited Epstein's home until after
+ended
+her connection to the financier in the summer of 1996. He said the passage would work to
+undermine her credibility moving forward.
+"It just shows that Boies is more interested in going after me" than in helping his own client,
+Dershowitz said in a brief phone interview.
+EFTA00040558
+
+Boies was not immediately available to comment Tuesday.
+A third plaintiff
+on Tuesday said that she was recruited by a fellow massage-
+therapy student in 2002 to interview for a traveling masseuse position with a wealthy
+couple in New York. After speaking with Epstein employee
+said she
+was flown to Manhattan, where she was to be housed at a 66th Street apartment, which
+housed "many of the models and other young women" Epstein was abusing.
+Soon after
+said, Epstein sexually assaulted her as she tried to leave the room after
+he pushed his foot into "her intimate parts" during a foot massage
+said she was so
+traumatized by the encounter that did not finish massage therapy school with the same
+certification that she initially set out to achieve and returned to Ohio shortly after the
+alleged assault.
+All three lawsuits named Darren Indyke, a longtime attorney for Epstein, and Richard
+Kahn, who were named executors of Epstein's estate following his apparent suicide in
+August. Indyke and Kahn are named solely as executors of the estate
+While Epstein's death in federal custody terminated the criminal case against him, plaintiffs
+have sued his estate for civil damages—a process experts have said could take years to
+complete.
+Prosecutors in Manhattan, meanwhile, say they are continuing to investigate whether any
+of Epstein's associates and employees could have been linked to the conspiracy.
+Public Affairs
+United States Department of Justice
+EFTA00040559
+
+EFTA00040560

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@@ -0,0 +1,15 @@
+From: "l
+To: "srichmanlaw@msn.com"
+Ce: "l
+Subject: Re: Mark Epstein
+Date: Mon, 28 Oct 2019 19:12:27 +0000
+Hi Stacey,
+Are you en route? Thanks.
+On Oct 24, 2019, at 10:55 AM,
+We are confirmed for a meeting at 3:00 p.m. on Monday at
+Assistant United States Attorney
+Southern District of New York
+Tel:
+• wrote:
+See you then. Thanks.
+EFTA00039662

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@@ -0,0 +1,51 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of New York
+MEMORANDUM
+TO:
+Acting Chief Financial Officer
+Executive Office of U.S. Attorneys
+FROM:
+Geoffrey S. Berman
+U.S. Attorney, Southern District of New York
+SUBJECT: Foreign Travel for AUSAs L
+DATE:
+January 23, 2020
+1, and
+This memo is intended to request approval for the planned foreign travel of
+hand
+Assistant United States Attorneys in the Southern
+District of New York.
+AUSAs
+I will be traveling to Stockholm,
+Sweden, to interview a potential witness in connection with an investigation into possible
+violations of 18 U.S.C. § 2423, among other offenses. AUSAs
+will travel between February 3 (overnight) and February 7, 2020.
+has approved this
+request.'
+In connection with the investigation of criminal conduct undertaken by Jeffrey Epstein
+and certain of his associates, we are investigating whether certain individuals undertook actions
+within the United States that involved the transportation of minors for the purpose of engaging in
+illicit sexual activity. The witness we intend to interview is a citizen and resident of Sweden
+and currently is unable to travel due to medical issues, but would be a potentially valuable
+Witness in our investigation. Specifically, the witness is the relative of a victim in the
+investigation, and may be able to significantly corroborate the victim as well as provide
+additional relevant information, including information required to meet certain elements of the
+crime(s) being investigated.
+Given the critical importance of the witness, and the need to fully debrief the witness over
+a one-day interview, and potentially a subsequent follow-up interview the following day, it is
+necessary for each of AUSAs
+to travel to Stockholm to participate
+in the interview.
+originally approved this trip for January 27 through 31st, but approval timelines
+necessitated rescheduling to the following week.
+EFTA00074185
+
+High Threat Security Overseas Seminar ("HTSOS"") training is required for the requested
+travel to Sweden. AUSAL
+has completed HTSOS training, and AUSAs
+and
+will complete the HTSOS training.
+AUSAs
+therefore request permission to travel to Sweden.
+EFTA00074186

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@@ -0,0 +1,17 @@
+From:
+To:
+Subject: RE: Call
+Date: Mon, 20 Sep 2021 16:38:07 +0000
+Inline-Images: image001 jpg; image002.jpg
+Hi - Want to talk today? When are you free?
+Sent. Thursday september 16/20215815AM1
+To:
+Subject: Call
+Good Morning
+Please let me know if you have a few minutes to speak with myself and SSA
+Thank you.
+regarding the Epstein case.
+Special Agent
+U.S. Department of Justice • Office of the Inspector General • New York Field Office
+New York, NY 10004
+EFTA00075851

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@@ -0,0 +1,49 @@
+From:
+(USANYS)" {
+To:
+Cc:
+(USANYS) [Contractor]"
+Subject: FW: Epstein
+Date: Thu, 11 Jul 2019 20:08:18 +0000
+Importance: Normal
+Assume we're not going to comment on how many calls we receive? I see her point, but not sure if that's a road we want
+to go down...
+From: Brown, Julie <
+Sent: Thursday, July 11, 2019 4:04 PM
+Tol
+(USANYS) <
+Subject: Re: Epstein
+I'm not asking what the communications are, as you know, I'm just
+asking for a statement about whether you received a response and
+whether that response was good. That is not asking you the nature
+of the calls or the communications.
+I hope we can have a good working relationship, and as I said, I'm
+willing to work within the confines of your restrictions.
+I too am getting calls from victims, and some of them are reluctant
+to go to your office because they've seen how the women in Florida
+were treated.
+It might be good to continue to use the media to assure them (and
+other potential witnesses) that you are truly on a different path than
+those who worked the previous case.
+I would appreciate it if you would share this email with Mr. Berman,
+and/or the lead prosecutors in the case.
+Thanks,
+JKB
+EFTA00076119
+
+On Thu, Jul 11, 2019 at 3:44 PM |
+(USANYS) <
+• wrote:
+Julie,
+Thank you for your inquiry. I cannot comment on how many victims have come forward or the nature or
+those calls; communications between victims and this Office are strictly confidential.
+Public Affairs
+United States Department of Justice
+U.S. Attorney's Office |Southern District of New York
+Mobile:
+| Press Office:
+Julie K. Brown
+Investigative Reporter
+The Miami Herald
+c)L
+EFTA00076120

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@@ -0,0 +1,7 @@
+From:
+To:
+Subject: search warrant
+Date: Sun, 07 Jul 2019 03:08:44 +0000
+Importance: Normal
+Attachments: Second_New_York_Residence_SW.v3.docx
+EFTA00071801

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@@ -0,0 +1,35 @@
+From: "
+To: "
+Cc: "
+(USANYS)" 4
+(USANYS)" 4
+Subject: RE: Epstein FOIA Atty Visit Logs and Count Slips
+Date: Sat, 09 Jan 2021 17:27:43 +0000
+(USANYS)"
+(USANYS)"
+Am I correct that the documents appear to fall under paragraph 2 of the Protective Order?
+From: |
+(USANYS) <
+Sent: Saturday, January 09, 2021 9:13 AM
+To: l
+(USANYS) <
+Cc:|
+| (USANYS) <
+Subject: Epstein FOIA Atty Visit Logs and Count Slips
+Defense counsel in Tartaglione has requested to see the attorney visit logs and count slips that have Tartaglione's name on
+them. Those documents may be covered by the attached protective order, and so we have asked
+, who is
+firewall counsel in Tartaglione, to receive the documents from you for potential production to defense counsel (so that
+and I do not see them).
+is going to review the protective order first and determine whether she needs
+Judge Karas to modify the order to allow her to receive the documents, so please don't send them to
+until she
+reaches out. Thanks for helping with this - we know it is a pain.
+Deputy Chief, White Plains Division
+United States Attorney's Office
+Southern District of New York
+300 Quarropas Street
+White Plains, New York 10601
+Tel:
+Cell:
+EFTA00066944

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vision-joined/ds9-unparsed-01/9129fc0ff7455fb2d58cebafa92162c8eec7c913de79491f141460c3be84a752.md

@@ -0,0 +1,964 @@
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page1 of 38
+UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT
+Thurgood Marshall U.S. Courthouse 40 Foley Square, New York, NY 10007 Telephone:
+MOTION INFORMATION STATEMENT
+Docket Number(s): 20-2413
+Motion for: Emergency Motion to Stay Pending Appeal
+Caption [use short title]
+Set forth below precise, complete statement of relief sought:
+Ms. Maxwell seeks a stay pending appeal, or
+in the alternative, a temporary administrative stay
+to afford this Court sufficient time to consider on the
+merits the motion to stay pending appeal
+v. Maxwell
+MOVING PARTY: Defendant-Appellant Ghislaine Maxwell OPPOSING PARTY: Plaintiff-Appellee
+Plaintiff
+/Appellant/Petitioner
+MOVING ATTORNEY: Adam Mueller
+V Defendant
+LAppellee/Respondent
+OPPOSING ATTORNEY: Sigrid McCawley
+[name of attorney, with firm, address, phone number and e-mail]
+Haddon, Morgan and Foreman, P.C.
+Boies Schiller & Flexner LLP
+Court- Judge/ Agency appealed from: Hon. Loretta A. Preska, District Judge (S.D.N.Y.)
+Please check appropriate boxes:
+Has movant notified opposing counsel (required by Local Rule 27.1):
+V Yes
+No (explain):
+FOR EMERGENCY MOTIONS, MOTIONS FOR STAYS ANI
+ves VINo
+Opposing counsel's position on motion:
+]Unapposed V OpposedDon't Know
+Does opposing counsel intend to file a response:
+Yes
+No V Don'tKnow
+Is oral argument on motion requested?
+Has argument date of appeal been set?
+Signature of Moving Attorney:
+s/ Adam Mueller
+Date: 7/30/2020
+• / No (requests for oral argument will not necessarily be granted)
+Yes / No If yes, enter date:
+Service by: V CM/ECF
+Other [Attach proof of service|
+Form T-1080 (rev. 12-13)
+EFTA00074903
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page2 of 38
+20-2413
+United States Court of Appeals
+for the Second Circuit
+Plaintiff-Appellee,
+-against-
+GHISLAINE MAXWELL,
+Defendant-Appellant,
+ON APPEAL FROM THE UNITED STATES DISTRICT COURT
+FOR THE SOUTHERN DISTRICT OF NEW YORK
+15-CV-7433 (LAP)
+Ghislaine Maxwell's Emergency Motion to Stay Pending Appeal
+or, in the Alternative, Motion for a Temporary Administrative
+Stay Pending Full Consideration of the Motion to Stay
+Ty Gee
+Laura Menninger
+Adam Mueller
+Anomeysgor Degenuum-Appenan Guste marDen
+EFTA00074904
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page3 of 38
+Table of Contents
+Table of Authorities..
+. ii
+Table of Exhibits.
+...V
+Introduction
+..1
+Statement of the Case and the Facts ..
+.. 2
+I. The defamation action and the Protective Order.
+. 2
+II. The motion to unseal and the first appeal.
+5
+III. The remand, the arrest, and the indictment.
+Argument.
+• 6
+13
+I. This Court should stay the district court's order pending appeal.
+13
+A. Ms. Maxwell will suffer irreparable harm absent a stay because the denial of
+a stay will moot her appeal....
+. 15
+B. Ms. Maxwell has more than a substantial possibility of success on the
+merits.
+17
+C. A stay will cause no meaningful harm to plaintiff or the Miami Herald.
+D. The public interest favors a stay.
+.25
+26
+Conclusion
+..29
+Certificate of Service..........
+.........31
+1
+EFTA00074905
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page4 of 38
+Table of Authorities
+Cases
+Blum v. Schlegel,
+108 F.3d 1369 (2d Cir. 1997)..
+Brown v. Maxwell,
+929 F.3d 41 (2d Cir. 2019).
+Dubose v. Pierce,
+487 U.S. 1229 (1988).
+Dubose ». Pierce,
+761 F.2d 913 (2d Cir. 1985)
+Gambale v. Deutsche Bank AG,
+377 F.3d 133 (2d Cir. 2004).
+Hilton v. Braunskill,
+481 U.S. 770 (1987).
+Hunt ». Enzo Biochem, Inc.,
+904 F. Supp. 2d 337 (S.D.N. Y. 2012)...
+In re Long Island Lighting Co.,
+129 F.3d 268 (2d Cir. 1997)..
+In re New York Times Co.,
+828 F.2d 110 (2d Cir. 1987)...
+In re Sims v. Blot,
+534 F.3d 117 (2d Cir. 2008).
+In re Teligent, Inc.,
+640 F.3d 53 (2d Cir. 2011).
+In revon Bulow,
+828 F.2d 94 (2d Cir. 1987)
+..12
+•passim
+... 15
+..15
+..16
+13
+.12
+..15
+. 20
+.14
+9
+14
+11
+EFTA00074906
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page5 of 38
+Martindell v. Int'l Tel. & Tel. Corp.,
+594 F.2d 291 (2d Cir. 1979) ..
+Mich. Coalition of Radioactive Material Users, Inc. v. Griepentrog,
+945 F.2d 150 (6th Cir. 1991).
+Mohammed v. Reno,
+309 F.3d 95 (2d Cir. 2002)...
+Nixons V. 89 Communications, hac,
+Nken v. Holder,
+556 U.S. 418 (2009)
+Patterson v. Colorado ex rel. Attorney General of Colo.,
+205 U.S. 454 (1907)
+Providence Journal Co. v. FBI
+595 F. 2d 889 (1st Cir. 1979)
+S.E.C. v. TheStreet.Com,
+273 F.3d 222 (2d Cir. 2001)
+S.F. Residence Club, Inc. v. 7027 Old Madison Pike, LLC,
+583 F.3d 750 (11th Cir. 2009).
+Scripps-Howard Radio v. F.C.C.,
+316 U.S. 4 (1942)..
+United States v. Amodeo,
+71 F.3d 1044 (2d Cir. 1995) .........
+United States v. Bolton,
+F. Supp. 3d
+2020 WL 3401940 (D.D.C. No. 1:20-CV-1580 (RCL), June 20, 2020)
+United States v. Erie Cty., N.Y.,
+763 F.3d 235 (2d Cir. 2014).
+• passim
+14
+13, 15,25
+18,19,20
+.27
+28
+14,16
+• 23,28
+16,27
+.........27
+.....18
+..12
+ili
+EFTA00074907
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page6 of 38
+United States v. Graham,
+257 F.3d 143 (2d Cir. 2001).
+United States v. McVeigh,
+119 F.3d 806 (10th Cir. 1997) ...
+Wash. Metro. Area Transit Comm'n v. Holiday Tours, Inc.,
+559 F.2d 841 (D.C. Cir. 1977).
+Statutes
+All Writs Act, 28 U.S.C. § 1651(a)..
+Other Authorities
+U.S. CONST. amend. V.
+U.S. CONST. amend. VI
+Rules
+Fed. R. App. P. 8(a) (2).
+FED. R. EVID. 401.
+FED. R. EVID. 402.
+FED. R. EVID. 403.
+FED. R. EVID. 404(b)....
+..12
+28
+13
+..27
+• 18,27
+18,27
+13
+28
+28
+28
+... ..
+EFTA00074908
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page7 of 38
+Table of Exhibits
+EXHIBIT 1: March 18, 2016 Protective Order (Dist. Ct. Doc. 062)
+ExHIBIT 2: July 1, 2020 Memorandum & Order (Dist. Ct. Doc. 1071)
+ExHIBIT 3: July 29, 2020 Motion to Reconsider by Ms. Maxwell & Exhibits (Dist.
+Ct. Docs. 1078 & 1078-1, 1078-2, 1078-3, 1078-4, 1078-5)
+EXHIBIT 4: June 10, 2020 Objection by Ms. Maxwell (Dist. Ct. Doc. 1056)
+ExHIBIT 5: June 24, 2020 Response by l
+Dist. Ct. Docs. 1068 & 1068-1)
+EXHIBIT 6: June 24, 2020 Response by Miami Herald (Dist. Ct. Doc. 1067)
+ExHIBIT 7: July 1, 2020 Reply by Ms. Maxwell & Decl. by Ms. Menninger in
+Support Thereof (Dist. Ct. Docs. 1073, 1074, and 1074-1, 1074-2, 1074-3, 1074-4)
+EXHIBIT 8: Transcript of July 23, 2020 Hearing
+EXHIBIT 9: July 29, 2020 Order Denying Ms. Maxwell's Motion to Reconsider
+(Dist. Ct. Doc. 1079)
+V
+EFTA00074909
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page8 of 38
+Introduction
+This case began as a defamation action, though it is hardly recognizable as
+such anymore. The stakes are much higher now.
+The government has indicted Ghislaine Maxwell. The media has all but
+convicted her.
+The government alleges, among other things, that Ms. Maxwell committed
+perjury during her civil deposition. But Ms. Maxwell sat for the deposition and was
+compelled to answer numerous personal, sensitive, and allegedly incriminatory
+questions only after the plaintiff and the district court, through a stipulated
+Protective Order, guaranteed the confidentiality of her answers. As this Court has
+long recognized, and as this case shows, "witnesses might be expected frequently
+to refuse to testify pursuant to protective orders if their testimony were to be made
+available to the Government for criminal investigatory purposes in disregard of
+those orders."1
+Now that promise of confidentiality appears to have been dubious at best.
+Indeed, it is at risk of being broken entirely.
+' Martindell v. Int'l Tel. & Tel. Corp., 594 F.2d 291, 296 (2d Cir. 1979).
+1
+EFTA00074910
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page9 of 38
+Without any apparent lawful basis, the government has obtained a copy of
+Ms. Maxwell's confidential, sealed deposition. The indictment quotes directly
+from it. And yesterday, the district court ordered its imminent unsealing.
+The district court's unsealing order sanctions the perjury trap unfairly set for
+Ms. Maxwell, in violation of the 5th Amendment privilege against self-
+incrimination. It risks Ms. Maxwell's due process right to a fair trial by an impartial
+jury. And it eviscerates the promise of confidentiality on which Ms. Maxwell and
+numerous third parties reasonably relied. Absent a stay from this Court, it will
+forever let the cat out of the bag.
+To vindicate Ms. Maxwell's constitutional right to remain silent, to protect
+her constitutional right to a fair trial by an impartial jury, and for all the other
+reasons offered below, this Court should stay the unsealing order pending appeal.
+Statement of the Case and the Facts
+I. The defamation action and the Protective Order.
+alleged that Ms. Maxwell defamed her. The alleged
+defamation centered on a statement from Ms. Maxwell's attorney generally
+denying as "untrue" and "obvious lies" plaintiff's numerous allegations, over the
+span of four years, that Ms. Maxwell participated in a scheme causing her to be
+"sexually abused and trafficked" by Jeffrey Epstein.
+2
+EFTA000749117
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page10 of 38
+Plaintiff, a public figure required to prove actual malice, litigated her
+defamation action by trying to transform it into a criminal or tort action for sexual
+abuse and sexual trafficking of minors. Her lawyers intended to prove the
+defamation claim solely by, in effect, "prosecuting" Ms. Maxwell as a proxy for
+Epstein. Plaintiff chose this course of action because even she admitted some of her
+public statements were false.
+Discovery in the case was correspondingly intrusive, hard-fought, and wide-
+ranging. It spanned more than a year and included voluminous document
+productions and responses to interrogatories and thirty-some depositions,
+including depositions of plaintiff and Ms. Maxwell as well as numerous third
+parties, including Doe 1.
+Plaintiff sought and obtained a wide variety of private and confidential
+information about Ms. Maxwell, Doe 1, and others, including information about
+financial and sexual matters. Given the amount of personal, confidential material
+and information exchanged between the parties during discovery, the district court
+entered a stipulated Protective Order protecting from public disclosure information
+the parties in good faith concluded was confidential. ExHIBIT 1. The Protective
+Order included a mechanism for one party to challenge another party's
+confidentiality designation (such a challenge never occurred) and expressly
+3
+EFTA00074912
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page11 of 38
+provided that it was not applicable to any information or material disclosed at trial.
+Id. at 4-5.
+"The Protective Order, despite the angst it is now causing, is unremarkable
+in form and function." EXHIBIT 2 at 3. Counsel for plaintiff originally proposed
+protective order language that would have allowed for a "law enforcement"
+exception. In particular, Paragraph I(a) 4 of the draft proposed that
+"CONFIDENTIAL information shall not be disclosed or used for any purpose
+except the preparation and trial of this case and any related matter, including but
+not limited to, investigations by law enforcement. " See EXHIBIT 3 at 42.
+This language was rejected by Ms. Maxwell because of her concerns that
+plaintiff and her lawyers were acting as either express or de facto agents of the
+government. The language agreed upon, and made an order of the district court,
+specifically excluded an exception for law enforcement. Had the language not been
+made an order of the district court, Ms. Maxwell would have proceeded in a
+different fashion. She instead relied on this language and the protection afforded to
+her by this Court under established Second Circuit law.
+After the district court denied Ms. Maxwell's motion for summary
+judgment, the parties agreed to a settlement of the defamation claim and the case
+was dismissed. As the district court below recognized, a significant component of
+4
+EFTA00074913
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page12 of 38
+the settlement agreement was its confidentiality, a feature that echoes the purpose
+of the Protective Order on which Ms. Maxwell and numerous third parties,
+including Doe 1, justifiably relied.
+II. The motion to unseal and the first appeal.
+One year after the case was dismissed and closed, the Miami Herald sought
+to reopen the case and to unseal every sealed filing on the district court docket. The
+district court denied the motion to unseal.
+The Miami Herald appealed, and this Court reversed. Brown v. Maxwell, 929
+F.3d 41, 44-45 (2d Cir. 2019). The majority concluded that the district court erred
+in sealing the summary judgment materials. Id. at 47-48. Upon the issuance of the
+mandate, it unsealed the summary judgment materials to the public and the press,
+and it remanded the case to the district court to conduct a particularized review of
+the remaining records to which the Herald sought access. Id. at 53-54.
+Judge Pooler dissented in part. Id. at 54. Although she agreed the district
+court erred, she would only have unsealed the summary judgment order while
+leaving "the remainder of the materials for the district court to review, redact, and
+unseal on remand." Id. (Pooler, J., dissenting in part).
+5
+EFTA00074914
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page 13 of 38
+Despite the division among the judges, the Court was unanimous in its
+recognition of "the potential damage to privacy and reputation that may
+accompany public disclosure of hard-fought, sensitive litigation." Id. at 44.
+Finally, anticipating that the district court would not have the last word
+about whether certain materials should remain under seal, this Court instructed
+that "[i]n the interests of judicial economy, any future appeal in this matter shall be
+referred to this panel. " Id. at 54.
+III. The remand, the arrest, and the indictment.
+On remand, the Miami Herald sought to unseal Ms. Maxwell's depositions
+(taken in April and July 2016) and the deposition of Doe 1 (taken in June 2016). Ms.
+Maxwell filed an objection, ExHIBIT 4, plaintiff and the Herald each filed a
+response, ExHIBIts 5 & 6, and Ms. Maxwell filed a reply, ExHIBIT 7.
+On July 2, one day after Ms. Maxwell filed her reply, the government staged
+a dramatic, forced entry at dawn into her home and arrested her. ExHIBIT 3 at 13.
+Immediately after Ms. Maxwell's arrest, Acting U.S. Attorney Audrey
+Strauss held a press conference and made numerous comments attacking Ms.
+Maxwell's credibility and expressing her opinion of Ms. Maxwell's guilt, e.g., that
+she was guilty of "[ying]" in her deposition "because the truth, as alleged, was
+almost unspeakable." Id.
+6
+EFTA00074915
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page14 of 38
+Plaintiff's counsel piled on, offering their own opinions about Ms. Maxwell's
+guilt. For example, Bradley Edwards opined that Ms. Maxwell was "a main
+facilitator" of Epstein's crimes who "started the whole thing." Id. And Sigrid
+McCawley praised the prosecutors: "[They] have done an incredible job and
+they're being very meticulous, they want to make sure that the Indictments
+stick... They took a lot of time to be very careful and thoughtful and that gives me
+a lot of hope that [Ms. Maxwell] will remain in prison for the remainder of her
+life.. [Ms. Maxwell] was really the central figure ...." Id. at 16.
+Ms. Maxwell's motion for an order barring such extrajudicial comments led
+Judge Nathan (S.D.N.Y.), who is presiding over the criminal case, to admonish
+"counsel for all involved parties [to] exercise great care to ensure compliance with
+this Court's local rules, including Local Criminal Rule 23.1, and the rules of
+professional responsibility." ExHIIT 3 at 19. Judge Nathan further "warn[ed]
+counsel and agents for the parties and counsel for potential witnesses that going
+forward [the court] will not hesitate to take appropriate action in the face of
+violations of any relevant rules." Id. Judge Nathan said she would ensure " strict
+compliance" with the rules and "ensure that the Defendant's right to a fair trial
+will be safeguarded." Id.
+7
+EFTA00074916
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page15 of 38
+On July 8, the government filed a superseding indictment alleging that Ms.
+Maxwell "assisted, facilitated, and contributed" to Epstein's abuse of minors. The
+indictment quickly turned to this civil action, alleging that in 2016 Ms. Maxwell
+made "efforts to conceal her conduct" by "repeatedly provid[ing] false and
+perjurious statements" in deposition testimony. ExHIIt 3 at 29 9 8.
+Quoting verbatim from Ms. Maxwell's April 2016 deposition transcript, the
+indictment alleges that Ms. Maxwell gave false testimony (a) when she testified "I
+don't know what you're talking about"' in response to a question whether Epstein
+"ha[d] a scheme to recruit underage girls for sexual massages ... [ilf you know";
+and (b) when she testified, "I'm not aware of anybody that I interacted with [other
+than plaintiff] who was 17 at this point." Id. at 35 9l 21.
+None of these questions and answers was used in the summary judgment
+materials released by this Court in Brown. The transcript containing this testimony
+is sealed.
+Only two parties — plaintiff and Ms. Maxwell —and their counsel had proper
+access to the transcripts of Ms. Maxwell's depositions. The transcripts, which were
+designated "confidential" under the Protective Order, could only be disclosed to
+"attorneys actively working on this case" and "persons regularly employed or
+associated with the attorneys who are working on this case." EXHIBIT 1 at 2. As
+8
+EFTA00074917
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page16 of 38
+explained above, this language was negotiated by the parties specifically to exclude
+an exception for investigations by law enforcement.
+From Ms. Maxwell's indictment and arrest, four things are plain. One, as
+the indictment and superseding indictment establish, the government has a copy of
+the transcripts from Ms. Maxwell's April and July 2016 depositions, both of which
+were designated "Confidential."
+Two, the government had no apparent ability legally to obtain the deposition
+transcripts. In Martindell v. International Telephone and Telegraph Corp., 594 F.2d
+291, 293 (2d Cir. 1979), cited with approval in In re Teligent, Inc., 640 F.3d 53, 58 (2d
+Cir. 2011), the government moved in a civil action to which it was not a party for
+access to transcripts of depositions of twelve witnesses, including some of the civil
+defendants. The government said it was investigating possible violations of federal
+criminal laws, including perjury, subornation of perjury, obstruction of justice, and
+conspiracy. The government:
+speculated that the pretrial deposition testimony might be relevant to
+its investigation into matters similar to those that had been the subject
+of the Martindell action and might be useful in appraising the
+credibility, accuracy and completeness of testimony given by witnesses
+in the Government's investigation or might provide additional
+information of use to the Government. The Government, moreover,
+feared that unless it could obtain the deposition transcripts, it would
+be unable to secure statements from the witnesses because they would
+claim their Fifth Amendment rights in any investigative interviews by
+the Government.
+9
+EFTA00074918
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page17 of 38
+594 F.2d at 293. The district court denied the government's request, holding that
+"the deposition testimony had been given in reliance upon the protective order,
+thus rendering unnecessary invocation by the witnesses of their Fifth Amendment
+rights, that the requested turnover would raise constitutional issues, and that
+principles of fairness mandated enforcement of the protective order." Id.
+On appeal, this Court affirmed:
+In the present case the deponents testified in reliance upon the Rule
+26(c) protective order, absent which they may have refused to
+testify... [T]he witnesses were entitled to rely upon the terms of a
+concededly valid protective order and Judge Conner did not abuse his
+discretion in refusing to vacate or modify that order.
+Id. at 296-97.
+Three, the government did not obtain a copy of the deposition transcripts
+from Ms. Maxwell or her counsel.
+Four, there has been a second violation of the district court's Protective
+Order consistent with the plaintiff's prior violation of the Protective Order:?
+' On July 1, the district court found a violation of the Protective Order by
+Plaintiff's attorneys after learning that her successor counsel, Cooper & Kirk, had
+received from her former counsel, Boies Schiller Flexner, various discovery
+materials that were subject to the Protective Order. EXHIBIT 2 at 4. The Court
+rejected Cooper & Kirk's suggestion that it properly was a recipient of the material:
+[W]hatever Cooper & Kirk's intentions in requesting and obtaining
+the Maxwell materials from Boies Schiller, the Maxwell Protective
+—footnote cont'd on next page —
+10
+EFTA00074919
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page 18 of 38
+On July 23, over Ms. Maxwell's objection, the district court ordered the
+complete unsealing of Ms. Maxwell's deposition transcripts and Doe 1's deposition
+transcript as well as numerous sealed or redacted orders and papers that quote
+from or disclose information from the transcripts (collective, the "deposition
+material"). That Ms. Maxwell was under criminal investigation, the court ruled,
+"is not entitled to much weight here." EXHIBIT 8 at 5.
+On July 28, the district court entered an order directing the public release of
+the deposition material on July 30.
+Docket Text:
+ORDER: The parties are directed to prepare for unsealing in accordance with the
+Court's order of July 23, 2020, (ECF Minute Entry, dated July 23, 2020), the
+documents listed in Exhibit A to Plaintiff
+Opposition to
+Defendant Ghislaine Maxwell's Objections to Onstaling Docket Entries 143, 164,
+172, 199, & 230, (dkt. no. 1068-1). Counsel shall file those documents on the public
+docket, under a heading of "Documents Ordered Unsealed by Order of July 23,
+2020," no later than July 30, 2020. The Court incorporates its rulings specific to
+each document-which are set forth in the transcript of the July 23 proceedings --
+herein. SO ORDERED. (Signed by Judge Loretta A. Preska on 7/28/2020) (va)
+Order explicitly provides that (1) discovery materials designated
+CONFIDENTIAL cannot be disclosed or used outside of the Maxwell
+action and (2) that properly designated discovery materials may only
+be disclosed to specific groups of individuals, including attorneys
+"actively working on" the Maxwell litigation.
+Id. at 4-5 (emphasis added). The district court ordered Cooper & Kirk to destroy
+"[a]ll of those materials and any material, including work product, derived"
+therefrom. Id. at 6. The court also ordered Cooper & Kirk to "cease use of the []
+materials in its preparation of Plaintiff's action against Mr. Dershowitz." Id.
+11
+EFTA00074920
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page19 of 38
+Ms. Maxwell filed a motion to reconsider on July 29, 2020. ExHIBIT 3.3 The
+motion asked the district court, should it deny the motion to reconsider, for a two-
+business-day stay of its order to permit Ms. Maxwell an opportunity to seek relief in
+this Court.
+The Court denied the motion to reconsider but stayed the unsealing until
+August 3, 2013. ExHIBIT 9.
+On July 29, 2020, Ms. Maxwell filed a notice of appeal from the district
+court's unsealing order.* This motion asks the Court to stay the unsealing of the
+deposition material pending resolution of that appeal.
+Because the district court intends to unseal the deposition material on
+August 3, 2020, absent a contrary ruling by this Court, Ms. Maxwell makes this
+motion on an emergency basis. To prevent irreparable harm, Ms. Maxwell
+3 As part of the motion to reconsider, Ms. Maxwell also asked the district
+court to commence contempt proceedings and issue an order to show cause why
+the person(s) who violated the Order should not be held in contempt. See, e.g.,
+Blum v. Schlegel, 108 F.3d 1369 (2d Cir. 1997); Hunt v. Enzo Biochem, Inc., 904 F.
+Supp. 2d 337, 340 (S.D.N.Y. 2012). EXHIBIT 3 at 4.
+4 This Court has jurisdiction over the order to unseal under the collateral
+order doctrine. Brown, 929 F.3d at 54; see United States v. Ere Cty., N. Y., 763 F.3d
+235, 238 n.5 (2d Cir. 2014); United States v. Graham, 257 F.3d 143, 147-48 (2d Cir.
+2001).
+12
+EFTA000749217
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page20 of 38
+respectfully requests an order on this motion by close of business on Friday, July
+31, 2020.
+At the very least, this Court should enter a temporary administrative stay to
+give itself sufficient time to consider the merits of Ms. Maxwell's motion to stay
+pending appeal.
+Argument
+I. This Court should stay the district court's order pending appeal.
+Federal Rule of Appellate Procedure 8 governs a motion for a stay pending
+appeal. Fed. R. App. P. 8(a)(2). Under that Rule, this Court will stay a district
+court order pending appeal after evaluating four criteria: the likelihood of success
+on the merits, irreparable injury if a stay is denied, substantial injury to the party
+opposing a stay if one is issued, and the public interest. Mohammed v. Reno, 309
+F.3d 95, 100 (2d Cir. 2002) (citing Hilton v. Braunskill, 481 U.S. 770, 776 (1987)).
+"The necessary 'level' or 'degree' of possibility of success will vary
+according to the court's assessment of the other [stay] factors." Id. at 101 (quoting
+Wash. Metro. Area Transit Comm'n v. Holiday Tours, Inc., 559 F.2d 841, 843 (D.C.
+Cir. 1977)). As a result, "The probability of success that must be demonstrated is
+inversely proportional to the amount of irreparable injury [appellant] will suffer
+absent the stay. Simply stated, more of one excuses less of the other." Id. (quoting
+13
+EFTA00074922
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page21 of 38
+Mich. Coalition of Radioactive Material Users, Inc. v. Griepentrog, 945 F.2d 150, 153
+(6th Cir. 1991)).
+Here, irreparable injury will occur if the district court's unsealing order is
+not stayed. Simply put, unless this Court grants a stay, any appeal of the order to
+unseal will be moot. See Providence Journal Co. v. FBI, 595 F.2d 889, 890 (1st Cir.
+1979) (irreparable injury when denial of a stay will moot appeal).
+As with the disclosure of privileged communications, once the deposition
+material is released, there is no way to "re-seal" the material or repair the damage
+done. See In re Sims v. Blot, 534 F.3d 117, 132 (2d Cir. 2008) ("'[A] remedy after
+final judgment cannot unsay the confidential information that has been revealed.'"
+(quoting In re von Bulow, 828 F.2d 94, 99 (2d Cir. 1987)). At that point,
+particularly in the Internet age, the horse is irrevocably out of the barn. See United
+States v. Bolton,
+_F. Supp. 3d_
+_, 2020 WL 3401940, at * 4 (D.D.C. No. 1:20-
+CV-1580 (RCL), June 20, 2020) (declining to enjoin publication of a book by
+former National Security Advisor John R. Bolton because copies were already
+released, the "horse is out of the barn," and "in the Internet age, even a handful of
+copies in circulation could irrevocably destroy confidentiality").
+Because irreparable damage will result from the improper and premature
+unsealing of the deposition material, Ms. Maxwell need only show "a substantial
+14
+EFTA00074923
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page22 of 38
+possibility, although less than a likelihood, of success" on the merits. Dubose v.
+Pierce, 761 F.2d 913, 920 (2d Cir. 1985), vacated on other grounds, 487 U.S. 1229
+(1988). A "substantial possibility" of success is "something less than 50 percent."
+Mohammed, 309 F.3d at 102.
+If the likelihood were more than 50 percent, the appellant would be
+required to persuade the stay panel that he was more likely than not to
+win the appeal before the merits panel, just to obtain the critical
+opportunity to maintain the status quo until the merits panel considers
+the appeal.
+Id.
+As elaborated below, Ms. Maxwell has more than a substantial probability of
+success. And in contrast to the irreparable injury Ms. Maxwell will suffer absent a
+stay, plaintiff and the Miami Herald will suffer no meaningful harm if this Court
+grants Ms. Maxwell's motion. Finally, the public interest favors a stay. This Court
+should issue a stay pending appeal of the district court's order unsealing the
+deposition material. See In re Long Island Lighting Co., 129 F.3d 268, 270 (2d Cir.
+1997) (stay of order compelling discovery of evidence).
+A. Ms. Maxwell will suffer irreparable harm absent a stay because the
+denial of a stay will moot her appeal.
+Ms. Maxwell will suffer irreparable harm absent a stay because her "right of
+appeal here will become moot unless the stay is continued pending determination
+of the appeal[]. Once the documents are [disclosed] pursuant to the lower court's
+15
+EFTA00074924
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page23 of 38
+order, confidentiality will be lost for all time. The status quo could never be
+restored." Providence Journal Co., 595 F.2d at 890. As this Court has recognized,
+stays pending appeal of orders to unseal are appropriate so that "[t]he genie is [not]
+out of the bottle." Gambale v. Deutsche Bank AG, 377 F.3d 133, 138, 144 & n.11 (2d
+Cir. 2004).
+In Providence Journal Co. v. Federal Bureau of Investigation, the First Circuit
+stayed pending appeal a district court order requiring disclosure to the Providence
+Journal of various documents reflecting the results of an unauthorized and illegal
+wiretap. Id. at 889. The First Circuit explained that litigants are entitled to
+meaningful appellate review, which demands the opportunity for the appellate
+court to "take a fresh look at the decision of the trial court before it becomes
+irrevocable." Id. at 890. A stay pending appeal was appropriate because the
+"[flailure to grant a stay [would have] entirely destroy[ed] appellants' rights to
+secure meaningful review." Id.
+The same logic applies here. Unless this Court stays the district court's
+order unsealing the deposition material, Ms. Maxwell will lose her right to obtain
+review of the district court's order. See S.F. Residence Club, Inc. v. 7027 Old
+Madison Pike, LLC, 583 F.3d 750, 756 (11th Cir. 2009) (dismissing appeal as moot
+because appellant failed to seek a stay precluding payment of funds to a third-party
+16
+EFTA00074925
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page24 of 38
+creditor). Disclosure of the deposition will moot Ms. Maxwell's challenge to its
+unsealing.
+This Court has already anticipated Ms. Maxwell's right to appeal an
+unsealing order. As noted above, in Brown this Court instructed that in the
+"interests of judicial economy, any future appeal in this matter shall be referred to
+this panel." Brown, 929 F.3d at 54. This Court would not have directed future
+appeals to be assigned to the same panel only to allow such an appeal to be mooted
+before the panel could even consider its merits.
+B. Ms. Maxwell has more than a substantial possibility of success on
+the merits.
+Ms. Maxwell has more than a substantial possibility of succeeding on her
+claim that the deposition material should not be unsealed.
+A presumptive right of access attaches to a document only if the document is
+a judicial record. Brown, 929 F.3d at 49. In turn, a document is a judicial record only
+if it is relevant to the performance of a judicial function. Id.
+Once an item is deemed relevant to the exercise of judicial power, "the
+weight to be given the presumption of access must be governed by the role of the
+material at issue in the exercise of Article III judicial power and the resultant value
+of such information to those monitoring the federal courts." Id. "[W]hile evidence
+introduced at trial or in connection with summary judgment enjoys a strong
+17
+EFTA00074926
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page25 of 38
+presumption of public access, documents that 'play only a negligible role in the
+performance of Article III duties' are accorded only a low presumption that
+'amounts to little more than a prediction of public access absent a countervailing
+reason. '" Id. at 49-50 (quoting United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir.
+1995)).
+Here, the deposition material was not part of the summary judgment record.
+Thus, the presumption of access attached to it is " somewhat lower than the
+presumption applied to material introduced at trial, or in connection with
+dispositive motions such as motions for dismissal or summary judgment." See id. at
+50. In turn, several countervailing interests rebut the lower presumption of access
+attaching to the deposition material.
+First, the deposition material should remain sealed to protect Ms. Maxwell's
+right to a fair trial. U.S. CONST. amend. V, VI. The decision in Nixon v. Warner
+Communications, Inc., 435 U.S. 589 (1978) shows why.
+In that case, members of the media moved the district court to release audio
+tapes admitted into evidence in the trial of four of President Nixon's former
+advisors. The media intended to copy the tapes for broadcasting and sale to the
+public. District Judge Sirica denied the motion, principally on the ground that the
+rights of the four defendants, who had been convicted and had filed notices of
+18
+EFTA00074927
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page26 of 38
+appeal, would be prejudiced if they prevailed in their appeals. 435 U.S. at 595, 602
+n.14. Judge Sirica noted that the transcripts of the audio tapes had been released to
+the public. Id. at 595. The D.C. Circuit Court of Appeals held Judge Sirica abused
+his discretion.
+The Supreme Court reversed the court of appeals and rejected the media's
+arguments that release of the tapes was required under the common law right of
+access and the First Amendment. The Court noted with approval "Judge Sirica's
+view" that "the public's 'right to know' did not ... overcome the need to
+safeguard the defendants' rights on appeal." Id. at 595; see id. at 602 n.14 (noting
+that "Judge Sirica's principal reason for refusing to release the tapes [was] fairness
+to the defendants, who were appealing their convictions"). The Court indicated
+that the public interests in access to the tapes properly were balanced against "the
+duty of the courts," id. at 602, including the duty to ensure fairness to the
+defendants, see id. at 602 n.14.
+In Nixon, the Court was properly concerned about the effect of unsealing
+materials notwithstanding that they were core judicial documents (audio tapes
+admitted into evidence at the merits trial). And the court continued to hold these
+concerns even after the defendants had been convicted and had launched appeals.
+The court recognized that the right to a fair trial is a compelling interest in
+19
+EFTA00074928
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page27 of 38
+"weighing the interests advanced by the parties in light of the public interests and
+the duty of the courts," Nixon, 435 U.S. at 602.
+Here, the unsealing of the deposition material would result in substantial
+negative media publicity and speculation in an Internet world in the same way that
+Judge Sirica found release of the audio tapes in Nixon would generate publicity and
+affect those defendants' right to a fair trial. See also In re New York Times Co.., 828
+F.2d 110, 116 (2d Cir. 1987) (recognizing "defendants' fair trial rights" as an
+"appropriate" basis for sealing material). The public's right of access to the
+deposition material is substantially outweighed by the compelling interest in
+ensuring Ms. Maxwell's right to a fair trial.
+Second, the deposition material should remain sealed to vindicate this
+Court's prohibition on the government breaching a protective order to gain access
+to deposition transcripts in a civil lawsuit. Martindell, 594 F.2d at 294. In
+Martindell, decided forty years ago, this Court held that the government "may not.
+.. simply by picking up the telephone or writing a letter to the court... insinuate
+itself into a private civil lawsuit between others." Id. The Court rejected the
+government's argument that the district court's "solicitude for the witnesses'
+Fifth Amendment" over the government's desire for the deposition transcripts
+was an abuse of discretion. Id. at 295. It held that "a more significant
+20
+EFTA00074929
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page28 of 38
+counterbalancing factor" is the civil rules' goal of encouraging witnesses to
+participate in civil litigation:
+Unless a valid Rule 26(c) protective order is to be fully and fairly
+enforceable, witnesses relying upon such orders will be inhibited from
+giving essential testimony in civil litigation, thus undermining a
+procedural system that has been successfully developed over the years
+for disposition of civil differences. In short, witnesses might be
+expected frequently to refuse to testify pursuant to protective orders if
+their testimony were to be made available to the Government for
+criminal investigatory purposes in disregard of those orders.
+Id. at 296. After balancing the interests at stake, the Court held that absent
+improvidence in issuing the protective order or some extraordinary circumstance
+or compelling need, witnesses must be permitted to rely on the protective order's
+enforceability. Id. The protective order should not be vacated or modified "to
+accommodate the Government's desire to inspect protected testimony for possible
+use in a criminal investigation, either as evidence or as the subject of a possible perjury
+charge." Id. (emphasis added).
+Unsealing the deposition material in this case would sanction a blatant
+Martindell violation. Throughout much of the first year of this litigation plaintiff
+through her counsel represented to the district court and defense counsel that
+plaintiff was privy to and participating in an ongoing criminal investigation in which
+Ms. Maxwell was a "person of interest." EXHIBIT 3 at 7. Toward that end plaintiff
+withheld documents responsive to defense discovery requests for any documents
+21
+EFTA00074930
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page29 of 38
+relating to such a criminal investigation; plaintiff asserted such documents were
+subject to a law enforcement, "investigative" or public interest "privilege." Id. In
+response to Ms. Maxwell's motion to compel the production of documents,
+plaintiff submitted the "law enforcement materials" ex parte and in camera to the
+district court. Id. Ms. Maxwell objected to the submission of the materials ex parte
+and in camera. Id. The district court denied the motion to compel. Id. The
+materials never have been produced to the defense.
+Based on plaintiff's claim of an ongoing investigation, Ms. Maxwell
+requested, prior to her deposition, that plaintiff disclose any alleged "on-going
+criminal investigation by law enforcement" or alternatively to stay this action
+pending completion of any such investigation. Id. at 7-8. In part, Ms. Maxwell
+needed information concerning any such investigation to assess "the impact on any
+5th Amendment privilege." Id. at 8. Judge Sweet denied that motion. The day
+before Ms. Maxwell's deposition, the Court ordered that "[a]ny materials that the
+plaintiff has with respect to any criminal investigations will be turned over [by
+plaintiff] except for any statements made by plaintiff to law enforcement
+authority." Id. Plaintiff produced no such materials and Ms. Maxwell was deposed
+the next day. Id. In reliance on the protective order which included no exception for
+any law enforcement need or subpoena and based on plaintiff's failure to disclose
+22
+EFTA000749317
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page30 of 38
+any "on-going criminal investigation" she did not assert the 5th Amendment
+during that deposition. Id.
+This history, culminating in plaintiff's gratuitously attaching the entire
+transcripts of both Ms. Maxwell's depositions to court submissions, and the
+government's unexplained possession of the sealed materials, after which they then
+charged Ms. Maxwell with perjury counts, suggest plaintiff in conjunction with the
+government sought to circumvent Martindell: they set a perjury trap for Ms.
+Maxwell when plaintiff took her deposition. Unsealing the deposition material
+would sanction the Martindell violation at the expense of Ms. Maxwell's 5th
+Amendment rights.
+Third, the deposition material should remain sealed to vindicate Ms.
+Maxwell and other individuals' reasonable reliance on the judicial promise of
+confidentiality. See S.E.C. v. TheStreet. Com, 273 F.3d 222, 229-31 (2d Cir. 2001)
+(recognizing the importance of reliance interests in assessing whether to allow
+access to sealed documents (citing Martindell, 594 F.2d at 296 (2d Cir. 1979)). Ms.
+Maxwell and numerous third parties, including Doe 1, reasonably relied on the
+Protective Order. Many of the approximately thirty depositions in this case were
+made possible only because of the Protective Order. The district court had to issue
+numerous orders compelling deposition testimony of third parties, which
+23
+EFTA00074932
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page31 of 38
+depositions took place only after everyone agreed on the record that the testimony
+would be confidential and sealed pursuant to the Protective Order.
+Indeed, plaintiff's counsel stipulated to the Protective Order in part to
+facilitate taking Ms. Maxwell's deposition, saying, "I just want [Ms. Maxwell's]
+deposition... It is that important to me." EXHIBIT 3 at 9. When that deposition
+finally occurred, on the advice of counsel, Ms. Maxwell declined to answer
+numerous questions regarding her consensual adult sexual activity, invoking her
+constitutional right to privacy. In response, plaintiff filed a motion to compel,
+telling the court "we have a protective order in place, and that assures Ms.
+Maxwell's right to privacy in answering those kinds of questions." Ms. Maxwell's
+Answer Brief, Doc. 95, Brown v. Maxwell, Case No. 18-2868 (2d Cir. Jan. 10, 2019),
+at 25. The district court accepted plaintiff's argument and compelled Ms. Maxwell
+to answer, saying, "the privacy concerns are alleviated by the protection order in
+this case drafted by the defendant." Id.
+Finally, as explained more fully in Ms. Maxwell's objection to the unsealing
+of the deposition material and the reply in support of the objection, ExHIBITs 4 & 7,
+the deposition material should remain sealed to prevent the abuse of court records
+and files and to avoid annoyance, embarrassment, oppression, and undue burden.
+To be sure, this Court has already implied as much. When, in Brown, this Court
+24
+EFTA00074933
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page32 of 38
+unsealed the summary judgment material, it redacted "deposition responses
+concerning intimate matters where the questions were likely only permitted —and
+the responses only compelled —because of a strong expectation of continued
+confidentiality." 929 F.3d at 48 n.22. The district court should not unseal material
+this Court already declined to unseal, particularly because the material this Court
+declined to unseal enjoyed a stronger presumption of access (because it was part of
+the summary judgment record) than the material the district court has elected to
+unseal wholesale (because it was not part of the summary judgment record).
+C. A stay will cause no meaningful harm to plaintiff or the Miami
+Herald.
+A stay will cause no meaningful harm to plaintiff or the Miami Herald.
+First, Ms. Maxwell's and Doe 1's depositions have been confidential since
+they were taken, more than four years ago in April, June, and July 2016. Moreover,
+neither plaintiff nor the Miami Herald sought to unseal any records in the district
+court for nearly a year after the underlying case was settled, dismissed, and closed
+in May 2017. In that context, keeping the deposition material sealed a little longer,
+until this appeal is decided, will not tangibly harm either plaintiff or Ms. Maxwell.
+See Mohammed, 309 F.3d at 102 n.11 (rejecting the Government contention of harm
+from delaying the removal of an alien petitioner because the contention
+EFTA00074934
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page33 of 38
+"substantially weakened" by the "gap of more than ten weeks between the District
+Court's continuation of the stay and the Government's motion to lift the stay").
+Second, expedited consideration of the appeal, on a timeline convenient to
+this Court, will mitigate any minimal harm that might result from a brief stay that
+merely preserves the status quo. This Court anticipated exactly this scenario in the
+Brown decision, directing that any future appeals be assigned to the same panel in
+"the interests of judicial economy." Brown, 929 F.3d at 54.
+Third, plaintiff stipulated to the confidentiality of the deposition material and
+induced Ms. Maxwell to rely on it (setting a perjury trap along the way). Plaintiff
+cannot claim to be harmed when all Ms. Maxwell wants is a meaningful
+opportunity to show she reasonably relied on the plaintiff and the district court's
+promise of confidentiality.
+For his part, Doe 1 also relied on the same promise of confidentiality in
+submitting to his deposition. All Ms. Maxwell is asking is that this Court have a fair
+opportunity to review the merits of the district court's decision before the
+deposition material is unsealed for all time.
+D. The public interest favors a stay.
+Finally, the public interest favors a stay.
+26
+EFTA00074935
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page34 of 38
+First, a stay protects this Court's role in the judicial process. Appellate
+courts have long exercised their right to "hold an order in abeyance while [they]
+assess[] the legality of the order." Nken v. Holder, 556 U.S. 418, 426 (2009). A stay
+pending appeal is simply a "means of ensuring that appellate courts can responsibly
+fulfill their role in the judicial process." Id. at 427; see also Scripps-Howard Radio v.
+F.C.C., 316 U.S. 4, 9-10 (1942) ("[I]t is reasonable that an appellate court should
+be able to prevent irreparable injury to the parties ... resulting from the premature
+enforcement of a determination which may later be found to have been wrong.").
+By contrast, were this Court to deny a stay, Ms. Maxwell's appeal will
+become moot upon unsealing of the deposition material, at which point this Court
+will lose jurisdiction over the appeal. See S.F. Residence Club, 583 F.3d at 756
+(dismissing appeal as moot because appellant failed to seek a stay precluding
+payment of funds to a third-party creditor). A stay serves the public interest by
+protecting this Court's jurisdiction. See Nken, 556 U.S. at 426 (citing the All Writs
+Act, 28 U.S.C. § 1651(a), as a "grant of authority to federal courts to 'issue all writs
+necessary or appropriate in aid of their respective jurisdictions and agreeable to the
+usages and principles of law. '").
+Second, a stay serves the public interest by helping to secure Ms. Maxwell a
+fair trial before an impartial jury. U.S. CONST. amends. V, VI. At her deposition,
+27
+EFTA00074936
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page35 of 38
+Ms. Maxwell was compelled to answer numerous questions about her private,
+consensual, and intimate conduct with other adults. Evidence of that conduct will
+not be admissible in Ms. Maxwell's criminal trial, because it is irrelevant and highly
+prejudicial. See FED. R. EVID. 401, 402, 403, 404(b); United States v. McVeigh, 119
+F.3d 806, 813 (10th Cir. 1997) (upholding district court's sealing of discovery
+materials deemed inadmissible at trial, holding that " disclosure of such [materials]
+would play a negative role in the functioning of the criminal process, by exposing
+the public generally, as well as potential jurors, to incriminating evidence that the
+law has determined may not be used to support a conviction"'). If her deposition is
+disclosed and her answers revealed —answers she offered only upon the promise of
+confidentiality — potential jurors will be irreparably biased against Ms. Maxwell,
+making it difficult if not impossible to seat a fair and impartial jury. See Patterson v.
+Colorado ex rel. Attorney General of Colo., 205 U.S. 454, 462 (1907) (opinion for the
+Court by Holmes, J.) ("The theory of our [trial] system is that the conclusions to
+be reached in a case will be induced only by evidence and argument in open court,
+and not by any outside influence, whether of private talk or public print.").
+Third, the public has a paramount interest in being able to rely on judicial
+promises of confidentiality unless and until the courts definitively rule that the
+promise of confidentiality is no longer enforceable. See S.E. C., 273 F.3d at 229-31
+28
+EFTA00074937
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page36 of 38
+(citing Martindell, 594 F.2d at 296 (2d Cir. 1979). Unless this Court grants a stay,
+Ms. Maxwell will not be able to test whether the district court correctly concluded
+that its promise of confidentiality was no longer binding.
+Conclusion
+At the conclusion of its decision in Brown, this Court offered a "cautionary
+note" to the public and the press:
+[C]ourt filings are, in some respects, particularly susceptible to fraud.
+For while the threat of defamation actions may deter malicious
+falsehoods in standard publications, this threat is non-existent with
+respect to certain court filings. This is so because, under New York
+law (which governs the underlying defamation claim here), absolute
+immunity from liability for defamation exists for oral or written
+statements made ... in connection with a proceeding before a court.
+Thus, although the act of filing a document with a court might be
+thought to lend that document additional credibility, in fact,
+allegations appearing in such documents might be less credible than
+those published elsewhere.
+[T]he media does the public a profound disservice when it
+reports on parties' allegations uncritically. We have previously
+observed that courts cannot possibly discredit every statement or
+document turned up in the course of litigation, and we have criticized
+the use by the media of the somewhat misleading term court records in
+referring to such items. Even ordinarily critical readers may take the
+reference to court papers as some sort of marker of reliability. This
+would be a mistake.
+29
+EFTA00074938
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page37 of 38
+Brown, 929 F.3d at 52-53 (footnotes and quotations omitted). This note of caution
+is even more apt today, now that the government has indicted Ms. Maxwell and the
+media circus is descending.
+Unless this Court stays the unsealing of the deposition material, there will be
+nothing to protect against uncritical reporting of the deposition material's contents,
+reporting that will only undermine the ability to secure a fair trial for Ms. Maxwell.
+This Court should stay pending appeal the district court's order unsealing
+the deposition material.
+July 30, 2020.
+Respectfully submitted,
+s/ Adam Mueller
+Ty Gee
+Laura Menninger
+Adam Mueller
+HADDON, MORGAN AND FOREMAN, P.C.
+Counsel for Defendant-Appellant Ghislaine
+Maxwell
+30
+EFTA00074939
+
+Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page38 of 38
+Certificate of Service
+I certify that on July 30, 2020, I served a copy of this Ghislaine Maxwell's
+Emergency Motion to Stay Pending Appeal or, in the Alternative, Motion for a
+Temporary Administrative Stay Pending Full Consideration of the Motion to Stay via
+CM/ECF, which will send notification of the filing to all counsel of record.
+s/ Stephanie Poole
+31
+EFTA00074940

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@@ -0,0 +1,15 @@
+From: "
+To: "
+Ce: "l
+(USANYS)" ≤
+AMA)" <
+Subject: Epstein
+Date: Fri, 30 Aug 2019 11:44:16 +0000
+D' ‹
+Hi
+Thanks again for reaching out. I'm copying
+AUSAs working the Epstein case. They are of course happy to talk to you.
+Thanks,
+and
+I, who are the
+EFTA00079931

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+Case 9:08-cv-80736-KAM Document 361-68 Entered on FLSD Docket 02/10/2016 Page 1 of 4
+EXHIBIT
+68
+EFTA00081329
+
+Case 9:08-cv-80736-KAM Document 361-68 Entered on FLSD Docket 02/10/2016 Page 2 of 4
+March 20, 2011
+To whom it may concern:
+I served as U.S. Attorney for the Southern District of Florida from 2005 through 2009. Over the
+past weeks, I have read much regarding Mr. Jeffrey Epstein. Some appears true, some appears
+distorted. I thought it appropriate to provide some background, with two caveats: (i) under
+Justice Department guidelines, I cannot discuss privileged internal communications among
+Department attorneys and (il) I no longer have access to the original documents, and as the
+matter is now nearly 4 years old, the precision of memory is reduced.
+The Epstein matter was originally presented to the Palm Beach County State Attorney. Palm
+Beach Police alleged that Epstein unlawfully hired underage high-school females to provide him
+sexually lewd and erotic massages. Police sought felony charges that would have resulted in a
+term of imprisonment. According to press reports, however, in 2006 the State Attorney, in part
+due to concerns regarding the quality of the evidence, agreed to charge Epstein only with one
+count of aggravated assault with no intent to commit a felony. That charge would have resulted
+in no jail time, no requirement to register as a sexual offender and no restitution for the underage
+victims.
+Local police were dissatisfied with the State Attorney's conclusions, and requested a federal
+investigation. Federal authorities received the State's evidence and engaged in additional
+investigation. Prosecutors weighed the quality of the evidence and the likelihood for success at
+trial. With a federal case, there were two additional considerations. First, a federal criminal
+prosecution requires that the crime be more than local; it must have an interstate nexus. Second,
+as the matter was initially charged by the state, the federal responsibility is, to some extent, to
+back-stop state authorities to ensure that there is no miscarriage of justice, and not to also
+prosecute federally that which has already been charged at the state level.
+After considering the quality of the evidence and the additional considerations, prosecutors
+concluded that the state charge was insufficient. In early summer 2007, the prosecutors and
+agents in this case met with Mr. Epstein's attorney, Roy Black. Mr. Black is perhaps best known
+for his successful defense of William Kennedy Smith. The prosecutors presented Epstein a
+choice: plead to more serious state felony charges (that would result in 2 years' imprisonment,
+registration as a sexual offender, and restitution for the victims) or else prepare for a federal
+felony trial.
+What followed was a year-long assault on the prosecution and the prosecutors. I use the word
+assault intentionally, as the defense in this case was more aggressive than any which I, or the
+prosecutors in my office, had previously encountered. Mr. Epstein hired an army of legal
+superstars: Harvard Professor Alan Dershowitz, former Judge and then Pepperdine Law Dean
+Kenneth Starr, former Deputy Assistant to the President and then Kirkland & Ellis Partner Jay
+Lefkowitz, and several others, including prosecutors who had formally worked in the U.S.
+08-80736-CV-MARRA
+001795
+EFTA00081330
+
+Case 9:08-cv-80736-KAM Document 361-68 Entered on FLSD Docket 02/10/2016 Page 3 of 4
+Attorney's Office and in the Child Exploitation and Obscenity Section of the Justice Department.
+Defense attorneys next requested a meeting with me to challenge the prosecution and the terms
+previously presented by the prosecutors in their meeting with Mr. Black. The prosecution team
+and I met with defense counsel in Fall 2007, and I reaffirmed the office's position: two years,
+registration and restitution, or trial.
+Over the next several months, the defense team presented argument after argument claiming that
+felony criminal proceedings against Epstein were unsupported by the evidence and lacked a basis
+in law, and that the office's insistence on jail-time was motivated by a zeal to overcharge a man
+merely because he is wealthy. They bolstered their arguments with legal opinions from well-
+known legal experts. One member of the defense team warned me that the office's excess zeal in
+forcing a good man to serve time in jail might be the subject of a book if we continued to
+proceed with this matter. My office systematically considered and rejected each argument, and
+when we did, my office's decisions were appealed to Washington. As to the warning, I ignored
+it.
+The defense strategy was not limited to legal issues. Defense counsel investigated individual
+prosecutors and their families, looking for personal peccadilloes that may provide a basis for
+disqualification. Disqualifying a prosecutor is an effective (though rarely used) strategy, as
+eliminating the individuals most familiar with the facts and thus most qualified to take a case to
+trial harms likelihood for success. Defense counsel tried to disqualify at least two prosecutors. I
+carefully reviewed, and then rejected, these arguments.
+Despite this army of attorneys, the office held firm to the terms first presented to Mr. Black in
+the original meeting. On June 30, 2008, after yet another last minute appeal to Washington D.C.
+was rejected, Epstein pled guilty in state court. He was to serve 18 months imprisonment,
+register as a sexual offender for life and provide restitution to the victims.
+Some may feel that the prosecution should have been tougher. Evidence that has come to light
+since 2007 may encourage that view. Many victims have since spoken out, filing detailed
+statements in civil cases seeking damages. Physical evidence has since been discovered. Had
+these additional statements and evidence been known, the outcome may have been different. But
+they were not known to us at the time.
+A prosecution decision must be based on admissible facts known at the time. In cases of this
+type, those are unusually difficult because victims are frightened and often decline to testify or if
+they do speak, they give contradictory statements. Our judgment in this case, based on the
+evidence known at the time, was that it was better to have a billionaire serve time in jail, register
+as a sex offender and pay his victims restitution than risk a trial with a reduced likelihood of
+success. I supported that judgment then, and based on the state of the law as it then stood and the
+evidence known at that time, I would support that judgment again.
+Epstein's treatment, while in state custody, likewise may encourage the view that the office
+should have been tougher. Epstein appears to have received highly unusual treatment while in
+jail. Although the terms of confinement in a state prison are a matter appropriately left to the
+08-80736-CV-MARRA
+001796
+EFTA00081331
+
+Case 9:08-cv-80736-KAM Document 361-68 Entered on FLSD Docket 02/10/2016 Page 4 of 4
+State of Florida, and not federal authorities, without doubt, the treatment that he received while
+in state custody undermined the purpose of a jail sentence.
+Some may also believe that the prosecution should have been tougher in retaliation for the
+defense's tactics. The defense, arguably, often failed to negotiate in good faith. They would
+obtain concessions as part of a negotiation and agree to proceed, only to change their minds, and
+appeal the office's position to Washington. The investigations into the family lives of individual
+prosecutors were, in my opinion, uncalled for, as were the accusations of bias and / or
+misconduct against individual prosecutors. At times, some prosecutors felt that we should just
+go to trial, and at times I felt that frustration myself. What was right in the first meeting,
+however, remained right irrespective of defense tactics. Individuals have a constitutional right to
+a defense. The aggressive exercise of that right should not be punished, nor should a defense
+counsel's exercise of their right to appeal a U.S. Attorney to Washington, D.C. Prosecutors must
+be careful not to allow frustration and anger with defense counsel to influence their judgment.
+After the plea, 1 recall receiving several phone calls. One was from the FBI Special Agent-In-
+Charge. He called to offer congratulations. He had been at many of the meetings regarding this
+case. He was aware of the tactics of the defense, and he called to praise our prosecutors for
+holding firm against the likes of Messrs. Black, Dershowitz, Lefkowitz and Starr. It was a proud
+moment. I also received calls or communications from Messrs. Dershowitz, Lefkowitz and
+Starr. I had known all three individuals previously, from my time in law school and at Kirkland
+& Ellis in the mid 90s. They all sought to make peace. I agreed to talk and meet with each of
+them after Epstein pled guilty, as I think it important that prosecutors battle defense attorneys in
+a case and then move on. I have tried, yet I confess that has been difficult to do fully in this case.
+The bottom line is this: Mr. Jeffrey Epstein, a billionaire, served time in jail and is now a
+registered sex offender. He has been required to pay his victims restitution, though restitution
+clearly cannot compensate for the crime. And we know much more today about his crimes
+because the victims have come forward to speak out. Some may disagree with the prosecutorial
+judgments made in this case, but those individuals are not the ones who at the time reviewed the
+evidence available for trial and assessed the likelihood of success.
+Respectfully,
+R. Alexander Acosta
+Former U.S. Attorney
+Sothern District of Florida
+08-80736-CV-MARRA
+001797
+EFTA00081332

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+From: "
+(USANYS)" <
+To: "
+(USANYS)" <
+Subject: RE: Times v BOP - Additional Production
+Date: Wed, 26 Aug 2020 20:15:13 +0000
+K thanks
+From:
+To:
+I (USANYS) <
+Sent: Wednesday, August 26, 2020 4:15 PM
+(USANYS) <
+Subject: RE: Times v BOP - Additional Production
+Got it, but some of these records relate directly to the July 23 incident. I will identify pages that refer to that incident or
+otherwise to his suicidality.
+From:
+(USANYS) <
+Sent: Wednesday, August 26, 2020 4:13 PM
+To:
+(USANYS) <
+Subject: RE: Times v BOP - Additional Production
+I think the position
+ultimately settled on is that medical records unrelated to things we care about (i.e., that aren't
+about suicidality or his ultimate suicide) are fine to produce.
+From:
+(USANYS) <
+Sent: Wednesday, August 26, 2020 4:11 PM
+To:
+| (USANYS) <
+Subject: FW: Times v BOP - Additional Production
+Are we okay with disclosing Epstein's medical records? Some of the records are directly related to the July 23 incident,
+although others relate to other conditions. I had thought that all of his medical records were being withheld.
+From:
+To:
+| (USANYS) <
+Sent: Wednesday, August 26, 2020 10:48 AM
+(USANYS) <
+(USANYS) <
+(USANYS) Y
+(USANYS) <
+(USANYS)
+Subject: RE: Times v BOP - Additional Production
+Yes, you should have seen all this before, but it now has BOP's has segmented redactions. As with prior rounds, 1 am
+circulating to the Crim teams and OIG before the production version actually goes out.
+This is mainly emails, but also includes at the start redacted medical records, not withheld in full under 7(A). Thanks.
+From:
+To:
+(USANYS) <
+Sent: Wednesday, August 26, 2020 10:39 AM
+(USANYS) <
+(USANYS) <
+(USANYS) <
+P:
+Pil
+(USANYS) <
+(USANYS)
+EFTA00072704
+
+Subject: RE: Times v BOP - Additional Production
+This is stuff we've seen before, you just want us to double check?
+From:
+To:
+(USANYS) <
+Sent: Wednesday, August 26, 2020 10:34 AM
+(USANYS) <
+(USANYS)
+(USANYS) <
+Subject: RE: Times v BOP - Additional Production
+(USANYS) <
+(USANYS)
+All,
+BOP has provided a production version of what I hope is the last set of documents to be released in Times v. BOP, 20-cv-
+833. I have saved the combined production file, named "2nd August 2020 Production, Times v BOP, 20-cv-833," here:
+from BOP\2nd August Production
+Could the teams please review and confirm that this file can be released to the Times? Given the timing, it would be best
+to release these by the end of the week. Please let me know if you don't think review by Friday will be possible.
+Thanks,
+From:
+To:
+(USANYS) <
+Sent: Saturday, August 8, 2020 12:35 AM
+(USANYS) <
+(USANYS) <
+Cc:
+(USANYS) <
+Subject: RE: Times v BOP - Additional Production
+This looks fine.
+From:
+| (USANYS) <
+Sent: Friday, August 7, 2020 6:20 PM
+(USANYS) ‹
+(USANYS) <
+(USANYS) <
+(USANYS) <
+(USANYS)
+P;
+(USANYS)
+Cc:
+(USANYS) <|
+Subject: Times v BOP - Additional Production
+Hi all,
+As you know, we agreed with the Times that BOP would produce some documents after the SJ papers were filed in Times
+v. BOP. It looks like it is going to take BOP through the end of next week to get the emails together. In the meantime, we
+are going to produce what should be the remaining non-email documents (with redactions) and a portion of the
+remaining emails.
+EFTA00072705
+
+The production version of these documents is attached here. Can you please review and confirm that it is okay for the
+attached to be sent to the Times? It should all be documents you've seen before-and I think I circulated most of the
+attached production version to you earlier this week. But there are now some new pages at the end—also not sure | got
+sign off from everyone on the production versions of the earlier stuff. We'd like to send this out by Tuesday, August 11, at
+latest if possible.
+Also, I'm copying DI
+to speed.
+here. I will be out 08/12-08/18, and as graciously agreed to cover this case while I am out.
+(If all goes according to plan, not much will be happening then anyway). Please copy her going forward so she can get up
+Thanks and have a great weekend,
+EFTA00072706

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+From:
+To: "
+D" <
+Subject: RE: Please see annexed Epstein Victim Letter
+Date: Wed, 11 Nov 2020 21:22:56 +0000
+Inline-Images: image001 jpg
+(USANYS)"
+Thanks
+We're going to forward the most recent letter to the FBI for them to arrange an initial screening interview.
+From:
+Sent: Tuesday, November 10, 2020 1:00 PM
+To:
+(USANYS) <
+Subject: FW: Please see annexed Epstein Victim Letter
+The original iteration of this ended up going through - see the attached thread. Among other issues, her counsel
+apparently advised a year ago that she was not in a position to be interviewed at the time, though it looks like |
+referred it to FBI in any event. Just FYI.
+From:
+To:
+Cc:
+(USANYS) <
+Sent: Tuesday, November 10, 2020 12:50
+(USANYS) <
+P;
+(USANYS) <
+Subject: FW: Please see annexed Epstein Victim Letter
+Please see the attached letter which appears to concern an Epstein/Maxwell victim. It
+was forwarded to civilian crime reports, but because it appears to concern a statutory
+victim of a case we have charged, CCR does not do anything (other than forward to
+. If not a victim, please let us know and we will process. Thanks.
+From:
+(USANYS) [Contractor] <
+Sent: Tuesday, November 10, 2020 12:44 PM
+To:
+(USANYS) <
+Subject: FW: Please see annexed
+• (USANYS) <
+Audrey received this letter. It is from a law firm and about a victim who may have been abused by Epstein and Maxwell.
+Best,
+From: Jennifer Freeman <
+Sent: Tuesday, November 10, 2020 12:27 PM
+To: Strauss, Audrey (USANYS) <
+EFTA00079593
+
+Cc:
+Subject: Please see annexed
+Stay well,
+Jennifer
+Jennifer Freeman
+Marsh Law Firm PLLC
+Direct Dial
+Skype for Business
+Recipient 2019 PowerPlay Advocacy Award
+Blog | Facebook | Iwitter | LinkedIn
+CONFIDENTIALITY NOTICE: The information contained in this message and any attachment is confidential
+and may be subject to the attorney-client privilege, or otherwise protected from disclosure by applicable law.
+Any disclosure, distribution, copying, or use of the information contained in this message or any attachment by
+anyone other than the intended recipient, regardless of address or routing, is strictly prohibited. If you are not the
+intended recipient, please telephone or email the sender and delete this message and any attachment from your
+system.
+IF YOU ARE NOT A CLIENT: This material is general information of'an educational nature and is not legal
+advice. This communication does not establish or constitute the retention of Marsh Law Firm PLLC for the
+provision of legal services, unless explicitly so stated herein. Any attached items, including the content of this e-
+mail, are offered "as is" with no guarantee as to their accuracy, timeliness, or completeness.
+EFTA00079594

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vision-joined/ds9-unparsed-01/91944dcb1de5e177c389c91cc22f00117320598ab46236739659115e7f8394f7.md

@@ -0,0 +1,51 @@
+From: "Stoddart, Allison"
+To: '
+Cc: "Sahni, Anjan"|
+(USANYS)"
+I" =
+D' <
+Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+Date: Fri, 08 Oct 2021 17:13:00 +0000
+Great. Thanks,
+4:30 today works for us. I'II send a calendar invite with dial-in information.
+Allison
+From:
+Sent: Friday, October 8, 2021 12:15 PM
+To: Stoddart, Allison d
+Cc: Sahni, Anjan
+(USANYS) <
+Subject: Re: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+EXTERNAL SENDER
+Hi Allison,
+I'm traveling for work for much of next week, but I'm available for a call anytime on Monday, or at 9 a.m. on Tuesday. I'm
+also available for a call this afternoon anytime from 4 pm onwards if that's easier.
+Thanks.
+On Oct 8, 2021, at 11:18 AM, Stoddart, Allison <Allison. Stoddart@wilmerhale.com> wrote:
+Could we find some time early next week to discuss? Are there certain windows that would work on
+Thanks, J
+your end?
+Thanks,
+Allison
+Allison Stoddart | WilmerHale
+From:
+Sent: Friday, October 8, 2021 10:01 AM
+To: Sahni, Anjan d
+| (USANYS) <|
+I; Stoddart, Allison 4
+P:
+EFTA00067063
+
+P;
+Subject: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+EXTERNAL SENDER
+Anjan, Allison,
+Hope you're both doing well. Following up on our last conversation, we wanted to send along a few documents in order
+to facilitate our conversation about identifying an appropriate witness from JP Morgan. Attached is a zip file containing a
+few draft exhibits. We are still working on finalizing exhibits, but we thought it made sense to start the conversation
+about this sooner rather than later. Please let us know if you have any questions or if a call would be useful.
+Thanks,
+Assistant United States Attorney
+Southern District of New York
+One Saint Andrew's Plaza
+New York, NY 10007
+EFTA00067064

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+Exhibit F
+EFTA00040089
+
+Case 1:10-cV-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 1 of 15
+COMPOSITE EXHIBIT A
+NON-PROSECUTION AGREEMENT AND
+ADDENDUM
+EFTA00040090
+
+Case 1:10-cV-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 2 of 15
+IN RE:
+INVESTIGATION OF
+JEFFREY EPSTEIN
+NON-PROSECUTION AGREEMENT
+IT APPEARING that the City of Palm Beach Police Department and the State
+Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter,
+the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey
+Epstein (hereinafter "Epstein");
+IT APPEARING that the State Attorey's Office has charged Epstein by indictment
+with solicitation of prostitution, in violation of Florida Statutes Section 796.07;
+IT APPEARING that the United States Attorney's Office and the Federal Bureau of
+Investigation have conducted their own investigation into Epstein's background and an
+offenses that may have been committed by Epstein against the United States from in o
+around 2001 through in or around September 2007, including:
+(1)
+knowingly and willfully conspiring with others known and unknown to
+commit an offense against the United States, that is, to use a facility or means
+of interstate or foreign commerce to knowingly persuade, induce, or entic
+minor females to engage in prostitution, in violation of Title 18, United States
+Code, Section 2422(b); all in violation of Title 18, United States Code, Section
+371;
+(2)
+knowingly and willfully conspiring with others known and unknown to travel
+in interstate commerce for the purpose of engaging in illicit sexual conduct, as
+defined in 18 U.S.C. § 2423(f, with minor females, in violation of Title 18,
+United States Code, Section 2423(b); all in violation of Title 18, United States
+Code, Section 2423(e);
+(3)
+using a facility or means of interstate or foreign commerce to knowingly
+persuade, induce, or entice minor females to engage in prostitution; in
+violation of Title 18, United States Code, Sections 2422(b) and 2;
+(4)
+Page 1 of 7
+EFTA00040091
+
+Case 1:10-cV-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 3 of 15
+of Title 18, United States Code, Section 2423(b); and
+(S) knowingly, in and aflecting interstate and foreign commerce, recruiting,
+enticing, and obtaining by any means a person, knowing that the person had
+not attained the age of 18 years and would be caused to engage in a
+commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title
+18, United States Code, Sections 1591(a)(1) and 2; and
+IT APPEARING that Epstein seeks to resolve globally his state and federal criminal
+liability and Epstein understands and acknowledges that, in exchange for the benefits
+provided by this agreement, he agrees to comply with its terms, including undertaking certain
+actions with the State Attorney's Office;
+IT APPEARING, after an investigation of the offenses and Epstein's background by
+both State and Federal law enforcement agencies, and after due consultation with the State
+Attorney's Office, that the interests of the United States, the State of Florida, and the
+Defendant will be served by the following procedure;
+following conditions and the requirements of this Agreement set forth below.
+If the United States Attomey should determine, based on reliable evidence, that,
+during the period of the Agreement, Epstein willfully violated any of the conditions of this
+Agreement, then the United States Attomey may, within ninety (90) days following the
+xpiration of the term of home confinement discussed below, provide Epstein with timel
+notice specifying the condition(s) of the Agreement that he has violated, and shall initiate it
+prosecution on any offense within sixty (60) days' of giving notice of the violation. Any
+notice provided to Epstein pursuant to this paragraph shall be provided within 60 days of the
+United States learning of facts which may provide a basis for a determination of a breach of
+the Agreement.
+After timely fulfilling all the terms and conditions of the Agreement, no prosecution
+Page 2 of 7
+EFTA00040092
+
+Case 1:10-cV-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 4 of 15
+Terms of the Agreement:
+1.
+2.
+4.
+6.
+Epstein shall plead guilty (not nolo contendere) to the Indictment as
+currently pending against him in the 15th Judicial Circuit in and for
+Palm Beach County (Case No. 2006-cf-009495AXXXMB) charging
+one (1) count of solicitation of prostitution, in violation of Fl. Stat. §
+796.07. In addition, Epstein shall plead guilty to an Information filed
+by the State Attorney's Office charging Epstein with an offense that
+requires him to register as a sex offender, that is, the solicitation of
+minors to engage in prostitution, in violation of Florida Statutes Section
+796.03;
+Epstein shall make a binding recommendation that the Court impose a
+thirty (30) month sentence to be divided as follows:
+(a) Epstein shall be sentenced to consecutive terms of twelve (12)
+months and six (6) months in county jail for all charges, without
+any opportunity for withholding adjudication or sentencing, and
+without probation or community control in lieu of
+Epstein shall be sentenced to a term of twelve (12) months of
+community control consecutive to his two terms in county jail
+as described in Term 2(a), supra.
+This agreement is contingent upon a Judge of the 15th Judicial Circuit
+ccepting and executing the sentence agreed upon between the Stat
+ttorney's Office and Epstein, the details of which are set forth in thi
+agreement.
+The terms contained in paragraphs 1 and 2, supra, do not foreclose
+Epstein and the State Attorney's Office from agreeing to recommend
+any additional charge(s) or any additional terms) of probetion and/or
+incarceration.
+Epstein shall waive all challenges to the Information filed by the State
+Attorney's Office and shall waive the right to appeal his conviction and
+sentence, except a sentence that exceeds what is set forth in paragraph
+(2), supra.
+Epstein shall provide to the U.S. Attorney's Office copies ofall
+Page 3 of 7
+EFTA00040093
+
+Case 1:10-cV-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 5 of 15
+7.
+8.
+proposed agreements with the State Attorney's Office prior to entering
+into those agreements.
+The United States shall provide Epstein's attorneys with a list of
+individuals whom it has identified as victims, as defined in 18 U.S.C.
+§ 2255, after Epstein has signed this agreement and been sentenced.
+Upon the execution of this agreement, the United States, in consultation
+with and subject to the good faith approval of Epstein's counsel, shall
+select an attorney representative for these persons, who shall be paid for
+by Epstein. Epstein's counsel may contact the identified individuals
+through that representative.
+If any of the individuals referred to in paragraph (7), supra, elects to
+file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the
+jurisdiction of the United States District Court for the Southern District
+lis right to contest liability and also waives his right 1o contest damag
+Ip to an amount as agreed to between the identified individual ar
+exclusively under 18 U.S.C. § 2255, and agrees to waive any othe
+laim for damages, whether pursuant to state, federal, or common law
+10.
+damages in any suit are not to be construed as an admission of any
+criminal or civil liability.
+Epstein's signature on this agreement also is not to be construed as an
+admission of civil or criminal liability or a waiver of any jurisdictional
+or other defense as to any person whose name does not appear on th
+list provided by the United States
+Except as to those individuals who elect to proceed exclusively unde
+18 U.S.C. § 2255, as set forth in paragraph (8), supra, neither Epstein'
+11.
+defense as to any person, whether or not her name appears on the lis
+provided by the United States.
+Epstein shail use his best efforts to enter his guilty plea and be
+Page 4 of 7
+EFTA00040094
+
+Case 1:10-cV-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 6 of 15
+12.
+sentenced not later than October 26, 2007. The United States has no
+objection to Epstein self-reporting to begin serving his sentence not
+later than January 4, 2008.
+Epstein agrees that he will not be afforded any benefits with respect to
+gain time, other than the rights, opportunities, and benefits as any other
+inmate, including but not limited to, eligibility for gain time credit
+based on standard rules and regulations that apply in the State of
+Florida. At the United States' request, Epstein agrees to provide an
+accounting of the gain time he cared during his period of
+incarceration.
+13.
+The parties anticipate that this agreement will not be made part of any
+public record. If the United States receives a Freedom of Information
+Act request or any compulsory process commanding the disclosure of
+the agreement, it will provide notice to Epstein before making that
+disclosure.
+Epstein understands that the United States Attorney has no authority to require the
+State Attorney's Office to abide by any terms of this agreement. Epstein understands that
+it is his obligation to undertake discussions with the State Attorney's Office and to use his
+best efforts to ensure compliance with these procedures, which compliance will be necessary
+to satisfy the United States' interest. Epstein also understands that it is his obligation to use
+his best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein's binding
+recommendation regarding the sentence to be imposed, and understands that the failure to
+do so will be a breach of the agreement.
+In consideration of Epstein's agreement to plead guilty and to provide compensation
+in the manner described above, if Epstein successfully fulfills all of the terms and conditions
+of this agreement, the United States also agrees that it will not institute any criminal charges
+against any potential co-conspirators of Epstein, including but not limited to
+outstanding grand jury subpoenas shall be deemed withdrawn.
+Page 5 of 7
+EFTA00040095
+
+Case 1:10-cV-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 7 of 15
+By signing this agreement, Epstein asserts and certifies that each of these terms is
+material to this agreement and is supported by independent consideration and that a breach
+of any one of these conditions allows the United States to elect to terminate the agreement
+and to investigate and prosecute Epstein and any other individual or entity for any and all
+federal offenses.
+By signing this agreement, Epstein asserts and certifies that he is aware of the fact that
+the Sixth Amendment to the Constitution of the United States provides that in all criminal
+prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further
+is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court
+may dismiss an indictment, information, or complaint for unnecessary delay in presenting
+a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein
+hereby requests that the United States Attorney for the Southern District of Florida defer such
+prosecution. Epstein agrees and consents that any delay from the date of this Agreement to
+the date of initiation of prosecution, as provided for in the terms expressed herein, shall be
+deemed to be a necessary delay at his own request, and he hereby waives any defense to such
+prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of
+the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the
+United States to a speedy trial or to bar the prosecution by reason of the running of the statute
+of limitations for a period of months equal to the period between the signing of this
+agreement and the breach of this agreement as to those offenses that were the subject of the
+grand jury's investigation. Epstein futher asserts and certifies that he understands that the
+Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all
+felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees
+and consents that, if a prosecution against him is instituted for any offense that was the
+subject of the grand jury's investigation, it may be by way of an Information signed and filed
+by the United States Attorney, and hereby waives his right to be indicted by a grand jury as
+to any such offense.
+///
+Page 6 of 7
+EFTA00040096
+
+Case 1:10-cV-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 8 of 15
+By signing this agreement, Epstein asserts and certifies that the above has been read
+and explained to him, Epstein hereby states that he understands the conditions of this Noz-
+Prosecution Agreement and agrees to comply with them.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Dated:
+By:
+ASSISTANT U.S. ATTORNEY
+JEFPREY EPSTEIN
+Dated:
+GERALD LEFCOURT, ESQ.
+COUNSEL TO JEFFREY EPSTEIN
+Dated:
+LILLY ANN SANCHEZ, ESQ.
+ATTORNEY FOR JEFFREY EPSTEIN
+Pago 7 of 7
+EFTA00040097
+
+Case 1:10-cv-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010
+Page 9 of 15
+By signing this agrecment, Epstein asserts and certifies that the above has been read
+and explained to him. Epstein hereby states that he understands the conditions of this Non-
+Prosecution Agreement and agrees to comply with them.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Dated:
+By:
+ASSISTANT U.S. ATTORNEY
+Dated:
+JEPFREY EPSTEIN
+Dared: 9/24/07
+-GERALD DEFCOURTESQ.
+COUNSEL TO JEFFREY EPSTEIN
+Dated: _
+LILLY ANN SANCHEZ, ESO.
+ATTORNEY FOR JEFFREY EPSTEIN
+Page 7 of 7
+EFTA00040098
+
+Case 1:10-cV-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 10 of 15
+By signing this agreement, Epstein asserts and certifies that the above has been read
+and explained to him. Epstein hereby states that he understands the conditions of this Non-
+Prosecution Agreement and agrees to comply with them.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Dated:
+By:
+ASSISTANT U.S. ATTORNEY
+Dated: _
+JEFFREY EPSTEIN
+Dated: _
+GERALD LEFCOURT, ESQ.
+Datod: 9-24-07
+TILLY ANN SANGIEZ, ESQ.
+ATTORNEY FOR JEFFREY EPSTEIN
+Page 7 of 7
+EFTA00040099
+
+Case 1:10-cv-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 11 of 15
+IN RE:
+INVESTIGATION OF
+JEFFREY EPSTEIN
+ADDENDUM TO THE NON-PROSECUTION AGREEMENT
+T APPEARING that the parties seck to clarify certain provisions of page paragraph paragraph
+of the Non-Prosecution Agreement (hereinafter "paragraph 7"), that agreement is modified a
+follows:
+7A.
+The United States has the right to assign to an independent third-party the responsibility
+for consulting with and, subject to the good faith approval of Epstein's counsel, selecting
+e attorney representative for the individuals identified under the Agreement. If th
+Inited States elects to assign this responsibility to an independent third-party, both th
+United States and Epstein retain the right to make good faith objections to the attorney
+representative suggested by the independent third-party prior to the final designation of
+the attorney representative.
+7B.
+The parties will jointly prepare a short written submission to the independent third-party
+regarding the role of the attorney representative and regarding Epstein's Agreement to
+pay such attorney representative his or her regular customary hourly rate for representing
+such vietims subject to the provisions of paragraph C, infra.
+7C.
+Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision, however, shall not
+obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus,
+If after consideration of potential settlements, an attorney representative elects to file a
+contested lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested
+remedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay reasonable
+attorneys foes and costs such as those contained in s 2255 to bear the costs of the attorney
+representative, shall cease.
+EFTA00040100
+
+Case 1:10-cV-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 12 of 15
+By signing this Addendum, Epstein asserts and certifies that the above has been read and
+explained to him. Epstein hereby states that he understands the clarifications to the Non-
+Prosecution: Agreement and agrees to comply with them.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Dated: 10/30/07
+By:
+ASSISTANT U.S. ATTORNEY
+JEFFREY EPSTETN
+Dated:
+GERALD LEFCOURT, ESQ.
+COUNSEL TO JEFFREY EPSTEIN
+Dated: _
+LILLY ANN SANCHEZ, ESQ.
+ATTORNEY FOR JEFFREY EPSTEIN
+EFTA00040101
+
+Case 1:10-cV-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 13 of 15
+By signing this Addendum, Epstein asserts and certifies that the above has been read and
+explained to him. Epstein hereby states that he understands the clarifications to the Nog-
+Prosccution Agreement and agrees to comply with them.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Dated: 10/30/07
+By
+ASSISTANT U.S, ATTORNEY
+Dated:_
+Do 0/09079
+JEPFREY EPSTEIN
+GERALD LEFCOURT ESQ
+COUNSEL TO JEFFREY EPSTEIN
+Dated: _..
+LILLY ANN SANCHEZ, ESQ.
+ATTORNEY FOR JEFFREY EPSTEIN
+EFTA00040102
+
+Case 1:10-cv-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 14 of 15
+By signing this Addendum, Epstein asserts and certifies that the above hes been read and
+explained to him. Epstein hereby states that he understands the clarifications to the Non-
+Prosecution Agreement and agrees to comply with them.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Dated: 10/30/07
+By
+ASSISTANT U.S. ATTORNEY
+Dated:_
+JEFFREY EPSTEIN
+Dated:
+GERALD LEFCOURT, ESQ.
+Dated: 10-29-07
+LILLY ANN SANCHEZ, ESQ.
+ATTORNEY FOR JEFFREY EPSTEIN
+EFTA00040103
+
+Case 1:10-cV-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 15 of 15
+Dac-07-07
+04:55pm
+Froe-Fowlar-thite Burnett
+3057888201
+T-066
+P.DD3/004 F-Q7E
+Afirmation
+I, Jeffmy B. Epstein do hertby re-effinn the Nob-Proscopion Agreement and Addendura in
+same dared Octaber 30, 2007.
+1/110
+Date
+EFTA00040104

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+From:
+To:
+(USANYS)" 1
+(USANYS) 3"
+Cc:
+(USANYS)"
+Subject: RE: [REMINDER] RE: Forfeiture Funding Requests for Next Year
+Date: Mon, 08 Apr 2019 22:02:37 +0000
+Importance: Normal
+Attachments: Epstein_FY20_Request_ Form-_Large Case_Related _Expenses.docx; FY20_Request_Form-
+Large_Case_Related_Expenses -_OnMessage.docx; FY20_Request_Form-
+Large_Case_Related_Expenses_
+- GEP.docx; FY20 Request Form-
+Large_Case_Related_Expenses_-_OnMessage(1).docx; FY20 _Request_Form-
+Large_Case_Related_Expenses_
+Large_Case_Related_Expenses_
+Large_Case
+_Related_Expenses.docx
+From: 1
+(USANYS)
+Sent: Monday, April 8, 2019 12:00 PM
+To:
+(USANYS)
+Subject: [REMINDER] RE: Forfeiture Funding Requests for Next Year
+Reminder to please send me your unit requests today. Thanks to all who have already sent theirs.
+United States Attorney's Office
+Southern District of New York
+From:
+To: L
+(USANYS) 3
+Sent: Tuesday, April 2, 2019 11:05 AM
+(USANYS) 1
+EFTA00067125
+
+11
+5)
+Subject: Forfeiture Funding Requests for Next Year
+Chiefs,
+As discussed yesterday at the Crim unit chiefs meeting, each year we obtain a substantial amount of funding for case
+expenses from forfeiture funds allocated by EOUSA.
+I will be compiling the Office's requests for such funding for
+FY2O (September '20 to September '21), which are due to EOUSA on April 12.
+Below is a description of the types of expenses covered, and attached are (1) requests submitted by all your units for last
+year as a starting point; and (2) a spreadsheet of all the requests by unit to make it easier to pull yours out; and (3) the
+FY20 Template Form to fill out for each case. Please complete (or have your AUSAs complete) the Form for each case
+where there could be significant expenses, and email them to me and Andrew by the end of next Monday, April 8. If you
+have line AUSAs fill the forms out, please gather them all together to send us in one batch, and make sure they do NOT
+send them direct to EOUSA via the email listed on the form.
+We can request funds to cover all manner of non-routine expenses, such as:
+(1) Outside vendors for financial analysis/tracing, document review and discovery support, forensic analysis, etc.
+(2) Expert consultants (but NOT expert witnesses for actual testimony, which comes from a different fund)
+(3) Data- or document-hosting
+(4) Large translation expenses
+(5) Foreign travel
+This is not an exhaustive list and we have been able to use this funding for a wide variety of expenses in the past, so you
+should consider anything you think may be helpful to an investigation. Any questions, just let us know.
+Thanks!
+United States Attorney's Office
+Southern District of New York
+EFTA00067126

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+From:
+(USANYS)" {
+To: Laura Menninger •
+Ce: Jeff Pagliuca
+<besternheim
+"ceverdell
+Subject: RE: US v. Maxwell - missing testifying witness materials
+Date: Mon, 08 Nov 2021 18:53:50 +0000
+Attachments: 3521-003.pdf; 3521-004. pdf
+We had inadvertently skipped 3521-003 in stamping the materials. Attached are the materials with the corrected stamps,
+as reflected in the index provided on Saturday.
+Thanks,
+From: Laura Menninger
+Sent: Saturday, November 6, 2021 5:53 PM
+To:
+(USANYS) <
+P;
+Cc: Jeff Pagliuca «
+; besternheiml
+I ceverdell
+Subject: [EXTERNAL] US v. Maxwell - missing testifying witness materials
+Counsel -
+We were not provided
+3521-003 material.
+Can you please confirm whether that was intentional, and if not, provide it?
+Thank you,
+Laura
+Laura A. Menninger | Partner
+Haddon, Morgan & Foreman, P.C.
+EFTA00068870

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vision-joined/ds9-unparsed-01/9269559591a67daf34f1f1081015413a6ce8dd77ac808cda9c5766c4914745d7.md

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+From: "
+To: Bruce Barket <
+Ce: Aida Leisenring <
+KOFFSKY
+, Tony Ricco <
+≥ BRUCE
+≥, John Diaz
+Subject: RE: Tartaglione - additional photos and videos
+Date: Fri, 20 Dec 2019 20:45:39 +0000
+We will inquire. If there is a particular piece of information or a prior communication with MCC that you have that you
+believe would be helpful in our discussions with MCC, we'd ask that you pass it along to the extent you can.
+Co-Chief, Narcotics Unit
+From: Bruce Barket <
+Sent: Friday, December 20, 2019 10:21 AM
+To:
+Cc: Aida Leisenring <
+>
+P; Tony Ricco +
+>; BRUCE KOFFSKY
+John Diaz d
+Subject: Re: Tartaglione - additional photos and videos
+Good morning,
+Thanks for tracking down the Surveillance video.
+We still have reason to believe that photographs and video were taken of the cell during the time the officers initially
+responded to the cell and shortly after Mr. Epstein was removed from the cell.
+In light of the miscommunication regarding the surveillance video we would ask that you check again on the other photos
+and video. Relatedly, we would like to view a log of all the photographs.
+Thank you. Enjoy the holiday.
+Bruce Barket
+Barket, Epstein, Kearon, Aldea & LoTurco
+Garden City, NY 11530
+Barket Epstein.com
+On Dec 19, 2019, at 5:42 PM,
+> wrote:
+All,
+EFTA00079552
+
+As you may have just seen in our letter filed on the docket, after further discussion with MCC, we found that the video
+was preserved upon your request and are working to obtain a copy. We will make it available for review at our Office,
+Tand I are both out next week, so it may not be available for your review until the New Year.
+United States Attorney's Office
+Southern District of New York
+One Saint Andrew's Plaza
+New York, New York 10007
+EFTA00079553

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+U.S. Department of Justice
+United States Attorney
+Southern District of New York
+The Silvin J. Mollo Building
+One Saint Andrew's Plaza
+New York, New York 10007
+December 18, 2020
+BY ELECTRONIC MAIL
+Christian Everdell, Esq.
+Mark Cohen, Esq.
+Cohen & Gresser LLP
+800 Third Avenue
+New York, NY 10022
+Laura Menninger, Esq.
+Jeffrey Pagliuca, Esq.
+Haddon, Morgan and Foreman, P.C.
+150 East Tenth Avenue
+Denver, CO 80203
+Bobbi Sternheim, Esq.
+Law Offices of Bobbi C. Sternheim
+33 West 19th Street-4th Fl.
+New York, NY 10007
+Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+Dear Counsel:
+Due to an error in Bates stamping, today we are reproducing the materials listed in the
+below index. These items were originally produced with incorrect Bates numbers that resulted in
+overlape concerners SON G. 02742184 righT GM 0274 no samped with
+An index of the materials contained in this production is below:
+Bates Start
+Bates End
+Summary Description
+Reproduction, Deutsche Bank materials
+SDNY_GM_02742184
+SDNY_GM_02742186
+relating to Jeffrey Epstein
+Reproduction, UBS Subpoena Return, 12-15-
+SDNY_GM_02742187 | SDNY_GM_02742302 |2020
+Confidential
+Designation
+EFTA00072714
+
+Page 2
+The Government recognizes that its discovery obligations are ongoing and will promptly
+produce any additional discoverable material of which it becomes aware. Please do not
+hesitate to reach out if you have any difficulty accessing these materials or if you wish to
+arrange a time to review physical items in the FBI's custody.
+Very truly yours,
+AUDREY STRAUSS
+Acting United States Attorney
+by:
+Assistant United States Attorneys
+EFTA00072715

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+}

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+From:
+(USANYS)"
+To:
+(USANYS)"
+Subject: Updates for you to add to
+Date: Mon, 01 Jul 2019 23:39:22 +0000
+Importance: Normal
+Attachments: PC_Unit_--_Short_Form_Update.7.2.19.docx
+EFTA00040713

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+}

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+Exhibit H
+EFTA00065669
+
+29 October, 2020
+The Honorable Alison J. Nathan
+United States District Court
+Southern District of New York
+United States Courthouse
+40 Foley Square
+New York, NY 10007
+Your Honor:
+This statement is in support of Ghislaine Maxwell's request for bail and her character.
+I Anne Holve am Ghislaine Maxwell's eldest sister, and eldest of the Maxwell siblings since our late
+eldest brother Michael, died after a car accident in 1961. I am 72 years old, a Graduate from Oxford
+University with a Modern Languages Degree (French and Italian). I trained as an Actor at the Central
+School of Speech and Drama and pursed an acting career for many years after that. Then went into
+Publishing for a few years and later on trained as a Montessori teacher teaching young children in
+schools for many years. In my early 40s, I began training as a Psychotherapist and am now a licensed
+therapist in the United Kingdom, specializing in Cognititive Behavioral Therapy and Clinical
+Hypnotherapy, with an active practice in North London. I am still working and have been in this
+profession for 20 years.
+I have of course known my sister Ghislaine since she was born when I was 14 years old and
+witnessed her develop into a lovely, energetic and capable young woman. Growing up with our very
+wealthy and successful father was definitely not an easy experience. He was highly domineering and
+exacting and quick to anger if we did not immediately jump and/or respond to his questions and
+demands. He could be intensely crushing of our dreams and efforts as we grew into young
+adulthood, and even after. But each of us, including Ghislaine, also learned a relentless work ethic
+and the importance of key moral values from both our parents such as "concentration, consideration
+and conciseness" - a favorite dictum of our father's but also and highly important too was the social
+training we all received in welcoming, no matter the inconvenience or the surprise to look after all
+our father's many guests who came every weekend from all over the world whilst we were growing
+up, including scientists, political figures and business leaders.
+We were all expected to entertain
+them. This might include playing tennis with them, showing them around the city of Oxford (where
+our home was) but for the most part it consisted of basically engaging in conversation with them and
+helping them to feel welcome and to enjoy their visit with our family.
+Though Ghislaine left the United Kingdom for America just before our father died, as did our twin
+siblings in the earlier decades, we have always remained close as a family and kept in contact. I know
+that many of my nieces and nephews and their friends have visited and benefitted from staying with
+Ghislaine during their vacations and for life experience over the years, and Ghislaine asked if our
+daughter would like to come over for a few months after she finished university over here. It was a
+EFTA00065670
+
+kind and generous invitation from her and we had no hesitation whatsoever in sending her to spend
+time with Ghislaine.
+I must attest to my utter shock at the arrest of my sister on the charges she is facing. From all I know
+of her and the family values we have all been brought up with and live our lives by, she would not be
+capable of such behavior. I never witnessed Ghislaine be violent or remotely sexually inappropriate
+with anybody of any age or gender, ever. She is a warm, loving and generous human being and 1 am
+told she is bearing up with great courage and fortitude inside the detention center and those are
+some of the qualities in her character that are sustaining her in her current awful circumstances. I
+believe she is innocent of the charges brought against her and determined to prove her innocence. I
+believe she wants nothing else but to fight these charges in court in July 2021 and to clear her name
+and therefore would never seek to flee anywhere if she were granted bail. She, like all people so
+charged, have a constitutional right to due process and indeed she has declared herself to be
+innocent of all charges. She is innocent until proven otherwise and she like all people so charged - is
+entitled to a fair trial by a jury of her peers.
+1, like all my brothers and sisters, have complete faith in Ghislaine's respect for the judicial process
+and in her determination to fight all the charges brought against her. I am certain and confident of
+Ghislaine's trustworthiness and of the importance of her achieving bail in order to properly be able
+to prepare her defense to the charges she faces.
+Yours respectfully,
+Ahme J.T. Holvé
+Anne Holve
+EFTA00065671