Epstein Secrets

isparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera : We are in the process of finalizing our response to the Maxwell/Rivera issue. We intend to explain that the discovery and counsel access accommodations that have been provided to Maxwell and Rivera, respectively, resul

nference calls obtained through the Federal Defenders. At the moment, there's not a concern, at least from Judge Engelmayer, that the amount of time Rivera has for videoconferences and electronic discovery review is insufficient for trial preparation, although defense counsel has stated that they may r

tify the appropriate declarant and draft an explanation for the Court. Best, Assistant United States Attorney United States Attorney's Office for the Southern District of New York One Saint Andrew's Plaza New York NY 10007 Tel: EFTA00013345 --- PAGE BREAK --- EFTA00013346

isparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera : We are in the process of finalizing our response to the Maxwell/Rivera issue. We intend to explain that the discovery and counsel access accommodations that have been provided to Maxwell and Rivera, respectively, resul

nference calls obtained through the Federal Defenders. At the moment, there's not a concern, at least from Judge Engelmayer, that the amount of time Rivera has for videoconferences and electronic discovery review is insufficient for trial preparation, although defense counsel has stated that they may r

tify the appropriate declarant and draft an explanation for the Court. Best, Assistant United States Attorney United States Attorney's Office for the Southern District of New York One Saint Andrew's Plaza New York, NY 10007 EFTA00023083 --- PAGE BREAK --- Tel: EFTA00023084

9-1230(L), 2002 WL 34244994, at *2 (2d Cir. Apr. 26, 2002); United States v. Salameh, 152 F.3d 88, 120 (2d Cir. 1998) (per curiam); United States v. Rivera, 844 F.2d 916, 923 (2d Cir. 1988). The Second Circuit has held that language nearly identical to that in Epstein's NPA is not enough to overcome th

Adhering to this binding authority, this Court thus concluded (and continues to conclude) that the NPA does not bind the U.S. Attorney's Office for the Southern District of New York. It thus provides Maxwell no defense in this case even if it would otherwise cover the conduct charged in the new counts in the S2 superseding indic

ierre-Louis, No. 16 CR 541 (CM), 2018 WL 4043140, at *6 (S.D.N.Y. Aug. 9, 2018); United States v. Vickers, No. 13-CR-128-A, 2014 WL 1838255, at *8 (W.D.N.Y. May 8, 2014); United States v. Sensi, No. 3:08-CR-253 (WWE), 2010 WL 2351484, at *3 (D. Conn. June 7, 2010). The sex trafficking charges are theref

Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera We are in the process of finalizing our response to the Maxwell/Rivera issue. We intend to explain that the discovery and counsel access accommodations that have been provided to Maxwell and Rivera, respectively, resul

ed on the recent bail opposition in the Maxwell case, I believe the differences in counsel/discovery access are as follows: Accommodation Maxwell Rivera Review of electronic discovery (NB: each defendant has laptop access) 13 hours per day/7 days per week (91 hours total) 3 hours per day/7 days

it a declaration, from an appropriate person at the BOP, explaining in more detail why the accommodations provided to Maxwell cannot be extended to Rivera. Based on the recent bail opposition in the Maxwell case, I believe the differences in counsel/discovery access are as follows: Accommodation Maxw

draft an explanation for the Court. EFTA00023077 --- PAGE BREAK --- Best, Assistant United States Attorney United States Attorney's Office for the Southern District of New York One Saint Andrew's Plaza New York NY moon Tel: EFTA00023078

ecesnseeenesnseeeeesnseenesnseees Neumeier v. Kuehner, 286 N.E.2d 454 (N.Y. 1972) ccs Redding v. Edwards, 569 F. Supp. 2d 129 (D.D.C. 2008) ........ Rivera v. Heyman, 157 F.3d 101 (2d Cir, 1998) eee Salahi v. Obama, 625 F.3d 745 (D.C. Cit, 2010) veces Samantar v. Yousuf, et al., 130 S. Ct. 2278 (2010) ee

r claims against these financial sponsors of terrorism. Statement Of Subject Matter and Appellate Jurisdiction The United States District Court for the Southern District of New York had subject matter jurisdiction over these actions pursuant to 28 U.S.C. § 1330, 1331, 1332, 1350, 1367, 1407, and 1605, 18 U.S.C. §§ 1964 and 2338,

rorist activities and to be affiliated with al-Qaeda. See Wyatt, 785 F. Supp. 2d at 647-48; see also Goldberg v. UBS AG, 660 F. Supp. 2d 410, 428-29 (E.D.N.Y. 2009) (finding that plaintiffs had “sufficiently pled that the defendant consciously disregarded the fact that it was supporting a terrorist organiza

Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera We are in the process of finalizing our response to the Maxwell/Rivera issue. We intend to explain that the discovery and counsel access accommodations that have been provided to Maxwell and Rivera, respectively, resul

erence calls obtained through the Federal Defenders. At the moment, there's not a concern, at least from Judge Engelmayer, that the amount of time Rivera has for videoconferences and electronic discovery review is insufficient for trial preparation, EFTA00013335 --- PAGE BREAK --- although defense

tify the appropriate declarant and draft an explanation for the Court. Best, Assistant United States Attorney United States Attorney's Office for the Southern District of New York One Saint Andrew's Plaza New York NY 10007 Tel: EFTA00013336

iver in our team's decision to request that she receive so much time to review her discovery. Based on my read of the transcript from this morning's Rivera conference, it sounds like Rivera is not even using all the time he has now. By contrast, my understanding is that Maxwell is using up the full time

tify the appropriate declarant and draft an explanation for the Court. Best, Assistant United States Attorney United States Attorney's Office for the Southern District of New York One Saint Andrew's Plaza New York NY 10007 Tel: EFTA00015974

Access for Ghislaine Maxwell and Justin Rivera EFTA00018659 --- PAGE BREAK --- : We are in the process of finalizing our response to the Maxwell/Rivera issue. We intend to explain that the discovery and counsel access accommodations that have been provided to Maxwell and Rivera, respectively, resul

tify the appropriate declarant and draft an explanation for the Court. Best, Assistant United States Attorney United States Attorney's Office for the Southern District of New York One Saint Andrew's Plaza New York NY moor Tel: EFTA00018662

to the contraband cellphone is a matter of public record. As for the I we've consulted with the MCC and softened that language to the effect that Rivera was in the SHU for a disciplinary issue, without referencing the specifics or the fact that From: =. (USANYS) •rz > Sent: Thursday, December 31,

tify the appropriate declarant and draft an explanation for the Court. Best, Assistant United States Attorney United States Attorney's Office for the Southern District of New York One Saint Andrew's Plaza New York NY 10007 Tel: EFTA00030062

to the contraband cellphone is a matter of public record. As for the I we've consulted with the MCC and softened that language to the effect that Rivera was in the SHU for a disciplinary issue, without referencing the specifics or the fact that From: =, (USANYS) •rz > Sent: Thursday, December 31,

tify the appropriate declarant and draft an explanation for the Court. Best, Assistant United States Attorney United States Attorney's Office for the Southern District of New York One Saint Andrew's Plaza New York NY 10007 Tel: EFTA00030067