Epstein Secrets

be heard, but also by affirmatively misleading Chief Judge McMahon, 2 To this day, Judge Preska—who is presiding over the Giuffre action since Judge Sweet's passing and is addressing the Protective Order on a daily basis as the parties brief what material should be unsealed—apparently does not know th

A: Motion to Compel Plaintiff to Disclose Alleged "On-going Criminal Investigations by Law Enforcement" or, In the Alternative, to Stay Proceedings. Giuffre v. Maxwell, No. 15-cv- 07433-RWS, Apr. 18, 2016 EXHIBIT B: Giuffre v. Maxwell, No. 15-cv-07433-RWS, Transcript, Apr. 21, 2016 EFTA00100291 Ghislaine Maxwell

n District of New York against Maxwell or Epstein's estate, the government deliberately chose not to intervene in the on-going unsealing process in Giuffre v. Maxwell. In the only other active SDNY case against Epstein, Doe v. Indyke, No. 20-cv-484-JLIC, the government intervened and moved to stay discovery, sayi

r. Cassell's pro hac vice motion, defense counsel challenged the grant because they believed him to be a witness. In deciding that challenge, Judge Sweet already received information on the attorney-client relationship between Mr. Cassell and Ms. Giuffre. (Giuffre v. Maxwell, ECF Nos. 80, 84.) Thus,

Benson Magistrate Judge Evelyn J. Furse Paul G. Cassell moves this Court to quash a subpoena issued to him by the defendant, Ghislaine Maxwell in Giuffre v. Maxwell, No. 1:15-cv-07433-RWS (S.D.N.Y. filed Sept. 21, 2015). (ECF No. 2.) Ms. Maxwell opposes the Motion to Quash. (ECF No. 8.) Mr. Cassell replied. (EC

stency, fairness, and efficiency to all parties to this Motion and the underlying litigation. Therefore, this Court ORDERS the Motion TRANSFERRED to Giuffre v. Maxwell, No. 1:15-cv- 07433-RWS (S.D.N.Y. filed Sept. 21, 2015). Virginia L. Giuffre filed the underlying case in September 2015. The parties have heavily

y 29, 2016 Meeting Exhibit 6: November 30, 2018 Email Exhibit 7: December 6, 2018 Email Exhibit 8: February 28, 2019 Government Letter to Judge Sweet Exhibit 9: February 28, 2019 Government Letter to Judge Netburn Exhibit 10: Transcript of April 22, 2016 Deposition Exhibit 11: Transcript of Jul

as aware, Doe v. Indyke was the "lone case in this District that has not yet been either resolved or stayed at this point. . . In 23 In particular, Giuffre v. Maxwell was resolved in 2017 and the determination of what material should remain sealed remains the only open issue. Accordingly, there is no more discover

by a stay in the Doe case because the outcome of the criminal case could resolve disputed issues in the Doe case. Such concerns are not present in Giuffre v. Maxwell. 57 EFTA00077689 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine M

a were the defendant's denials of various sexual activities, not honest answers that would have been quite different. In part for that reason, Judge Sweet authorized the deposition at the outset. Second, the Government was not a party to the civil unsealing litigation and did not have an opportunity t

on in ordering the unsealing of the deposition materials and that Maxwell's interests outweighed the public's interests in access to the materials. Giuffre v. Maxwell, No. 20-2413 (2d Cir.), (Dkt. No. 140-1 at 2). On October 19, 2020, the Second Circuit found that Judge Preska "correctly held that the deposition m

on a motion to dismiss without the benefit of the full factual record. The motion should be denied. allegations that were central to the dispute in Giuffre v. Maxwell." (Def. Mot. 4, Ex. I at 7:3-6.) (The last colloquy has been unsealed except for Minor Victim-2's name. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1).)

y 29, 2016 Meeting Exhibit 6: November 30, 2018 Email Exhibit 7: December 6, 2018 Email Exhibit 8: February 28, 2019 Government Letter to Judge Sweet Exhibit 9: February 28, 2019 Government Letter to Judge Netburn Exhibit 10: Transcript of April 22, 2016 Deposition Exhibit 11: Transcript of Jul

as aware, Doe v. Indyke was the "lone case in this District that has not yet been either resolved or stayed at this point. . . In 23 In particular, Giuffre v. Maxwell was resolved in 2017 and the determination of what material should remain sealed remains the only open issue. Accordingly, there is no more discover

by a stay in the Doe case because the outcome of the criminal case could resolve disputed issues in the Doe case. Such concerns are not present in Giuffre v. Maxwell. 57 EFTA00039504 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine M

a were the defendant's denials of various sexual activities, not honest answers that would have been quite different. In part for that reason, Judge Sweet authorized the deposition at the outset. Second, the Government was not a party to the civil unsealing litigation and did not have an opportunity t

on in ordering the unsealing of the deposition materials and that Maxwell's interests outweighed the public's interests in access to the materials. Giuffre v. Maxwell, No. 20-2413 (2d Cir.), (Dkt. No. 140-1 at 2). On October 19, 2020, the Second Circuit found that Judge Preska "correctly held that the deposition m

on a motion to dismiss without the benefit of the full factual record. The motion should be denied. allegations that were central to the dispute in Giuffre v. Maxwell." (Def. Mot. 4, Ex. I at 7:3-6.) (The last colloquy has been unsealed except for Minor Victim-2's name. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1).)

me provisions and adding language that confidential material could be disclosed to law enforcement. (Def. Mot. 3, Ex. B).31 On March 18, 2016, Judge Sweet entered a protective order governing the discovery and dissemination of confidential information after the parties agreed to the form of the order o

stayed at this point. . . In particular, this matter appears to be the only remaining active civil case in this District in which 23 In particular, Giuffre v. Maxwell was resolved in 2017 and the determination of what material should remain sealed remains the only open issue. Accordingly, there is no more discover

by a stay in the Doe case because the outcome of the criminal case could resolve disputed issues in the Doe case. Such concerns are not present in Giuffre v. Maxwell. 57 EFTA00095149 claims against Ghislaine Maxwell have been asserted." (20 Civ. 484 (DCF) (JGK), Dkt. No. 80 at 2). The defendant's baseless con

a were the defendant's denials of various sexual activities, not honest answers that would have been quite different. In part for that reason, Judge Sweet authorized the deposition at the outset. Second, the Government was not a party to the civil unsealing litigation and did not have an opportunity t

ess attaches, and did not abuse its discretion in rejecting Maxwell's meritless arguments that her interests superseded the presumption of access." Giuffre v. Maxwell, No. 20-2413 (2d Cir.) (Dkt. No. 140-1 at 3).43 On October 22, 2020, the defendant's April 2016 deposition was publicly filed. (See 15 Civ. 7433 (L

Count Six, stating that the "testimony is .. . far afield from the sex trafficking and sexual abuse allegations that were central to the dispute in Giuffre v. Maxwell." (Def. Mot. 4, Ex. I at 7:3-6.) (The last colloquy has been unsealed except for Minor Victim-2's name. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1).)

hat the Court deny the request for leave to file any motion regarding the protective order, as any such motion would be properly addressed to Judge Sweet—the Judge who entered the order in the first instance. Jane Doe 43 furthers requests that the Court deny the requested stay of briefmg on the Motion

. Koelti July 17, 2017 Page 2 With regard to Epstein's request that he be given leave to move for modification of the protective order entered in Giuffre v. Maxwell, No. 15 Civ. 7433 (RWS), any issues related to the protective order are properly addressed to Judge Sweet. See, e.g., Daniels v. City of N. Y., 200

S-cv-07433 United States District Court For the Southern District of New York March 17, 2016 Protective Order by United States District Court Judge Sweet The undersigned acknowledges that he has read the above-referenced Protective Order, a copy of which is attached, and agrees to be bound by the prov

way of additional background information, shortly after Plaintiff initiated the Action, she was deposed in another matter pending in this District, Giuffre v. Maxwell, No. 15 Civ. 7433 (RWS) (the "Giuffre action"). During that deposition, Plaintiff gave sworn testimony which relates in large measure to the claims