Epstein Secrets

nd Jane Doe 2's abuse to the FBI on August 7, 2007. (DE 407 at ¶ 6.) From January of 2007 through September of 2007, discussions took place between the U.S. Attorney's Office for the Southern District of Florida ("the Office") and Jeffrey Epstein's attorneys. (DE 407 at ¶ 9.) On February I, 2007, Epstein's defense team se

ed about the civil compensation provision of the NPA the next day: In accordance with the terms of the Non-Prosecution Agreement, on June 30, 2008, the United States Attorney's Office provided you with a list of thirty-one individuals "whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstei

.S.C. § 3771(e) (the CVRA defines a victim as "a person directly and proximately harmed as a result of the commission of a Federal offense"); In re Stewart, 552 F.3d 1285, 1288 (1 1 ik Cir. 2008) ("to determine a crime victim, then, first, we identify the behavior constituting 'commission of a Federal o

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

ppeared a second time before Judge McMahon in April 2019. Ex. E. Judge McMahon held that conference for one reason: to learn "about contacts between the United States Attorney's Office and the Boies Schiller law firm prior to the issuance of the subpoena." Ex. E, p 2. The Assistant U.S. Attorney told Judge McMahon that the governme

s Clause to Suppress All Evidence Obtained from the Government's Subpoena to Boies Schiller and to Dismiss Counts Five And Six upon the following: U.S. Attorney's Office, SDNY One Saint Andrew's Plaza New York, NY 10007 s/ Christian R. Everdell 18 EFTA00011474

District of New York. Contrary to the government's portrayal of events, what happened here is that a prosecutor from the public corruption unit of the United States Attorney's Office, in an a parte proceeding, affirmatively misled Chief Judge McMahon to circumvent a Protective Order entered by one of her colleagues. The prosecut

dmits the following facts are true: • On February 29, 2016, AUSA M, the Human Trafficking Coordinator and Project Safe Childhood Coordinator for the U.S. Attorney's Office for the Southern District of New York, Ex. J, p 1, met with Peter Skinner of Boies Schiller, Stan Pottinger, and Brad Edwards, who represented M,

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

District of New York. Contrary to the government's portrayal of events, what happened here is that a prosecutor from the public corruption unit of the United States Attorney's Office, in an a parte proceeding, affirmatively misled Chief Judge McMahon to circumvent a Protective Order entered by one of her colleagues. The prosecut

] or anyone else." Id. 7 Two other aspects to the privilege log are notable: (a) In the litigation, Boies Schiller did not produce its emails with the U.S. Attorney's Office to Maxwell, despite the fact that they were directly responsive to a Request for Production of Documents Maxwell served just a couple of weeks afte

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

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

ppeared a second time before Judge McMahon in April 2019. Ex. E. Judge McMahon held that conference for one reason: to learn "about contacts between the United States Attorney's Office and the Boies Schiller law firm prior to the issuance of the subpoena." Ex. E, p 2. The Assistant U.S. Attorney told Judge McMahon that the governme

Discussion As described above, the Government has produced Brady, Giglio, and Rule 16 material in the possession of the prosecutors and agents at the United States Attorney's Office, the FBI, and the DOJ-OIG who have worked on this investigation and prosecution. Thomas seeks materials that are not in the possession of the Unite

); United States v. Raniere, No. 18 Cr. 204 (NGG), Dkt. 622 (precluding argument regarding propriety of Government's prosecution), United States v. Stewart, Cr. No. 03-717 (MGC), 2004 WL 113506, at *1 (S.D.N.Y. Jan. 26, 2004) (granting motion to preclude the defendant from "presenting arguments or evide

ed about the civil compensation provision of the NPA the next day: In accordance with the terms of the Non-Prosecution Agreement, on June 30, 2008, the United States Attorney's Office provided you with a list of thirty-one individuals "whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstei

.S.C. § 3771(e) (the CVRA defines a victim as "a person directly and proximately harmed as a result of the commission of a Federal offense"); In re Stewart, 552 F.3d 1285, 1288 (11th Cir. 2008) ("to determine a crime victim, then, first, we identify the behavior constituting 'commission of a Federal off

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

ppeared a second time before Judge McMahon in April 2019. Ex. E. Judge McMahon held that conference for one reason: to learn "about contacts between the United States Attorney's Office and the Boies Schiller law firm prior to the issuance of the subpoena." Ex. E, p 2. The Assistant U.S. Attorney told Judge McMahon that the governme

Discussion As described above, the Government has produced Brady, Giglio, and Rule 16 material in the possession of the prosecutors and agents at the United States Attorney's Office, the FBI, and the DOJ-OIG who have worked on this investigation and prosecution. Thomas seeks materials that are not in the possession of the Unite

); United States v. Raniere, No. 18 Cr. 204 (NGG), Dkt. 622 (precluding argument regarding propriety of Government's prosecution), United States v. Stewart, Cr. No. 03-717 (MGC), 2004 WL 113506, at *1 (S.D.N.Y. Jan. 26, 2004) (granting motion to preclude the defendant from "presenting arguments or evide