Epstein Secrets

N VANGIESON,ANN GIBSON,SUSAN STEWARD,CAMPBELL GURRENTZ,MARTIN A SIRIGOTI

ALLEN,JOSEPH FISHER,MARJORIE S SCHELLER,DR ZBIGNIEW PAGLIARI,RICHARD A KIER

ed by FBI Agent Linda Stewart, which itself was based on the reports and investigation of FBI Agent William Brown. Id. at 1208. Unbeknownst to Agent Stewart, Agent Brown's Second Circuit in Brown v. Maxwell held a few months after Judge McMahon's ruling that Maxwell had reasonably relied on the Protecti

t the Government's investigation. Moreover, the Assistant United States Attorney has represented to this Court that he has no idea what is in Boies Schiller's files, and that for all he knows every witness who was deposed stood on his/her Fifth Amendment rights and refused to answer questions. Id. at 21

21, 2017) 17 Martindeli v. Intl Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979) 12, 13 S.E.C. v. TheStreet.Com, 273 F.3d 222 (2d Cir. 2001) 12 Stewart v. Hudson Hall LLC, 20 Civ. 885 (SLC), 2020 WL 7239676 (S.D.N.Y. Dec. 9, 2020) 12 United States v. Avellino, 136 F.3d 249 (2d Cir. 1998) 16 United

aw firm had provided that information well before the investigation began. The government did indeed have previous contact with the firm. And Boies Schiller was instrumental in fomenting the Maxwell prosecution. The record is surpassingly clear: But for the government's misrepresentation, witting or not

1 FACTUAL BACKGROUND 2 A. The Protective Order in v. Maxwell 2 B. Maxwell's April and July 2016 depositions 4 C. The Settlement And Boies Schiller's Refusal To Comply With The Protective Order 6 D. The Government's False Statements To Judge McMahon 6 E. Judge Netburn Separately Rejects An

21, 2017) 17 Martindeli v. Intl Tel. & Tel. Cotp., 594 F.2d 291 (2d Cir. 1979) 12, 13 S.E.C. v. TheStreet.Com, 273 F.3d 222 (2d Cir. 2001) 12 Stewart v. Hudson Hall LLC, 20 Civ. 885 (SLC), 2020 WL 7239676 (S.D.N.Y. Dec. 9, 2020) 12 United States v. Avellino, 136 F.3d 249 (2d Cir. 1998) 16 United

law firm had provided that information well before the investigation began. The government did indeed have previous contact with the firm. And Pomp Schiller was instrumental in fomenting the Maxwell prosecution. The record is surpassingly clear: But for the government's misrepresentation, witting or not

21, 2017) 17 Martindeli v. Intl Tel. & Tel. Cotp., 594 F.2d 291 (2d Cir. 1979) 12, 13 S.E.C. v. TheStreet.Com, 273 F.3d 222 (2d Cir. 2001) 12 Stewart v. Hudson Hall LLC, 20 Civ. 885 (SLC), 2020 WL 7239676 (S.D.N.Y. Dec. 9, 2020) 12 United States v. Avellino, 136 F.3d 249 (2d Cir. 1998) 16 United

McMahon that the prosecutors had no idea what was in Boies Schiller's file. Indeed, he insisted, there had been no contact whatsoever between Boies Schiller and United States Attorney's Office before the government commenced its investigation. Nor, said the prosecutor, did Boies Schiller have any role in

aw firm had provided that information well before the investigation began. The government did indeed have previous contact with the firm. And Boies Schiller was instrumental in fomenting the Maxwell prosecution. The record is surpassingly clear: But for the government's misrepresentation, witting or not

1 FACTUAL BACKGROUND 2 A. The Protective Order in v. Maxwell 2 B. Maxwell's April and July 2016 depositions 4 C. The Settlement And Boies Schiller's Refusal To Comply With The Protective Order 6 D. The Government's False Statements To Judge McMahon 6 E. Judge Netburn Separately Rejects An

21, 2017) 17 Martindeli v. Intl Tel. & Tel. Cotp., 594 F.2d 291 (2d Cir. 1979) 12, 13 S.E.C. v. TheStreet.Com, 273 F.3d 222 (2d Cir. 2001) 12 Stewart v. Hudson Hall LLC, 20 Civ. 885 (SLC), 2020 WL 7239676 (S.D.N.Y. Dec. 9, 2020) 12 United States v. Avellino, 136 F.3d 249 (2d Cir. 1998) 16 United

stify the government's secret, ex parte application . Ex. H, p 6. Judge Netburn also implicitly recognized what Judge McMahon never knew—that Boies Schiller was all too eager for the government to investigate and prosecute Maxwell: 6 Maxwell has not yet been provided discovery of whether Boies Schiller s

appeared before Judge McMahon barely four months later, however, he told her none of this, unequivocally and falsely disavowing any role by Boies Schiller in fomenting the investigation and denying any contacts between Boies Schiller and his office before November 2018. Even though AUSA had a "complet

bscribed by FBI Agent Linda Stewart, which itself was based on the reports and investigation of FBI Agent William Id. at 1208. Unbeknownst to Agent Stewart, Agent Second Circuit in v. Maxwell held a few months after Judge McMahon's ruling that Maxwell had reasonably relied on the Protective Order's gu

appeared before Judge McMahon barely four months later, however, he told her none of this, unequivocally and falsely disavowing any role by Boies Schiller in fomenting the investigation and denying any contacts between Boies Schiller and his office before November 2018. Even though AUSA had a "complet

ed by FBI Agent Linda Stewart, which itself was based on the reports and investigation of FBI Agent William Brown. Id. at 1208. Unbeknownst to Agent Stewart, Agent Brown's Second Circuit in Brown v. Maxwell held a few months after Judge McMahon's ruling that Maxwell had reasonably relied on the Protecti