Epstein Secrets

The defendant's motion is, at its core, premised on a false factual narrative. The defendant alleges, based on a New York Daily News article, that Boies Schiller and the Government colluded starting in at least early 2016 with the "precise[] design[]" of having the defendant "charged with perjury." (Def. Mot

.D.N.Y. 1973) 73 United States v. Dorvee, 616 F.3d 174 (2d Cir. 2010) 236 United States v. Drago, No. 18 Cr. 0394 (SJF) (AYS), 2019 WL 3072288 (E.D.N.Y. July 15, 2019) 86 United States v. Dumitru, No. 18 Cr. 243 (LAK), 2018 WL 3407703 (S.D.N.Y. June 26, 2018) 261 United States v. Eldred, 933 F.3

bit 3: Exhibit 4: Exhibit 5: Exhibit 6: Exhibit 7: Exhibit 8: Exhibit 9: Exhibit 10: Exhibit 11: Exhibit 12: Notes from the U.S. Attorney's Office for the Southern District of New York June 14, 2007 Email November 2020 Report, U.S. Department of Justice, Office of Professional Responsibility Notes from February 11, 2021 Call Note

ase The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA") between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida (the "USAO-SDFL"). (Def. Mot. 1). She does so despite the fact that: (1) she did not negotiate the NPA, was not a party to the NPA, and

thereo is fore the Court. Attorneys and Law Firms *566 Sigrid S. McCawley, Boies, Schiller & Flexner LLP, Fort Lauderdale, FL, Joshua Schiller, Boies Schiller Flexner LLP, New York, NY, for Plaintiff. Arthur Louis Aidala, Law Offices of Aidala & Bertuna, P.C., Brooklyn, NY, Christian Kiely, Howard M. Coo

can give a plaintiff time to find a new attorney to represent her without delaying trial. Gorbaty v. Wells Fargo Bank N.A., 2011 WL 318090, at *3 (E.D.N.Y. Feb. 1, 2011); [ Gleason v. Zocco 941 F. Supp. 32, 36 (S.D.N.Y. 1996) (noting that granting a motion to disqualify "immediately after the action

ative defense that a plaintiff has a right to rebut, it is not appropriate for resolution on a motion to dismis Maxwell 165 F. Supp. 3d 147, 155 (S.D.N. . e Court of Appeals has said that if "the defendant's reply was made in bad faith ... the defense fails" and that "[i]t is the function of the j

From: Nicholas (USANYS) Sent: Thursday, November 14, 2019 11:05 AM To: (USANYS) < >; (USANYS) Cc: (USANYS) [Contractor) .c .) Subject: NYU 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

ng 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 Dershowit

ees could have been linked to the conspiracy. EFTA00040565 IIIIIIIIIIIIIIIII Public Affairs United States Department of Justice U.S. Attorney's Office I Southern District of New York EFTA00040566

ed in the abuse, under the guise of a massage. Both of the are represented in the litigation by David Boies, Joshua Schiller and Sigrid McCawley of Boies 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 upsta

nesses. F rom USANYS) Sent: Thursday, November 14, 2019 11:05 AM To: (USANYS) (USANYS) Cc: (USANYS) [Contractor] Subject: NYU 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

of Epstein's associates and employees could have been linked to the conspiracy. Public Affairs United States Department of Justice U.S. Attorney's Office I Southern District of New York EFTA00040559 EFTA00040560

ng 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 Dershowit

otential witnesses. From (LISANYS) Sent: urs ay,November 14, 2019 11:05 AM To: USANYS) < (USANYS) Cc: USANYS) [Contractor] Subject: NYU > 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

sociates and employees could have been linked to the conspiracy. EFTA00040571 Public Affairs United States Department of Justice U.S. Attorney's Office 'Southern District of New York EFTA00040572

NY 10021-4102. Page 3 EFTA00091018 ActionLog 09/13/2019 Case logged in. 09/16/2019 : Reformatted request, cut and pasted from pdf. Note that Boies Schiller has made multiple requests, including to other districts, on behalf of their client and this will need to be looked at under the Privacy Act as we

Request ACTIVE All records regarding, concerning or relating to a deceased individual named Jeffrey Edward Epstein maintained by the US Attorney's Office for the Southern District of New York and/or the US Attorney's Office for the Southern District of Florida. Mr. Epstein was born on January 20, 1953 and died on or about August 10,2019.

death. As Jeffrey Epstein is now deceased, any privacy concerns are extinguished. 1. Any and all records from the from the United States Attorney's Office for the Southern District of New York relating to: a. Jeffrey Epstein (DOB: 01/20/53); b. Ghislaine Maxwell DOB: 12/25/61 ; c. . Mark E stein; Page 8 EFTA00091023 in.

The defendant's motion is, at its core, premised on a false factual narrative. The defendant alleges, based on a New York Daily News article, that Boies Schiller and the Government colluded 60 EFTA00095152 starting in at least early 2016 with the "precise[] design[]" of having the defendant "charged with

WL 5090039 (S.D.N.Y. Oct. 10, 2014) 83 2016 WL 107841 (N.D. Tex. Jan. 11, 2016) 18, 19 2016 WL 1055737 (S.D.N.Y. Mar. 10, 2016) 2019 WL 3072288 (E.D.N.Y. July 15, 2019) 2020 WL 3483702 (S.D.N.Y. June 26, 2020) 2021 WL 78235 (January 11, 2021) Albright v. Oliver, 510 U.S. 266 (1993) Andover Data Se

ase The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA") between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida (the "USAO-SDFL"). She does so despite the fact that: (1) she did not negotiate the NPA, was not a party to the NPA, and her name is not

tion 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 Order explicitly provides that (1) discovery materials designated CONFIDENTIAL cannot be EFTA00075057 Caest 131-63.403481

the public interests and the duty of the courts," Nixon, 435 U.S. at 602. See United States v. Cicale, No. 05-CR-60-2 (NGG), 2018 WL 388941, at *3 (E.D.N.Y. Jan. 11, 2018) ("Compelling interests warranting closure of a courtroom—and, by extension, sealing of court documents— `may include the defendant's

elitheffffefilagtegtataf 8 The Honorable Alison J. Nathan July 21, 2020 Page 7 Respectfully Submitted, Jeffrey S. Pagliuca cc: U.S. Attorney's Office for the Southern District of New York Mark Cohen Christian Everdell Cohen & Gresser LLP Laura A. Menninger Haddon, Morgan & Foreman, P.C. EFTA00075071 Cagesle120o140ZaUX.PertDo&Af

tion 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 Order explicitly provides that (1) discovery materials designated CONFIDENTIAL cannot be EFTA00094806 Case 1:15-cv-07433-

the public interests and the duty of the courts," Nixon, 435 U.S. at 602. See United States v. Cicale, No. 05-CR-60-2 (NGG), 2018 WL 388941, at *3 (E.D.N.Y. Jan. 11, 2018) ("Compelling interests warranting closure of a courtroom—and, by extension, sealing of court documents— `may include the defendant's

Boies it was issued. The materials provided by Boies Schiller inclnin addition tIl inscripts of Maxwell and other individuals, materials proday N/14!IME lles, and court-relatedpleadings in the ase. 7. Magi

er for "distinct criminal acts where they originated from a common scheme." United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 5113139, at *2 (E.D.N.Y. Oct. 19, 2018) (citing Werner, 620 F.2d at 927). Specifically in the context of perjury, "[t]he law in this circuit clearly supports the joinder of