Epstein Secrets

No. S I 03 CR. 987DAB, 2009 WL 1585776 (S.D.N.Y. June 8, 2009) 18 United States v. Rajaratnam, 719 F.3d 139 (2d Ck. 2013) 18 United States v. Valentine, 820 F.2d 565 (2d Cir. 1987) 16 Young v. United States, 481 U.S. 787 (1987) 16 ii EFTA00086660 Other Authorities Norman Mailer, "An Appeal

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

68 (KBF), 2014 WL 5090039 (S.D.N.Y. Oct. 10,2014) 118,275 United States v. Urena, 989 F. Supp. 2d 253 (S.D.N.Y. 2013) 28, 171 United States v. Valentine, 820 F.2d 565 (2d Cir. 1987) 156,157,158 United States v. Valona, 834 F.2d 1334 (7th Cir. 1987) 66 United States v. Vickers, 708 F. App'x 732

r 18, 2018. Shortly thereafter, in or about December or January 2018, the Government indicated to at I that it intended to make document requests. Schiller generally advised the Government that a protective order would govern some of the materials. (Id. at 3). In or about February 2019, approximately t

r specified what "fundamental right" the Government allegedly violated nor provided legal authority supporting her claim. She cites United States v. Valentine, 820 F.2d 565, 570 (2d Cir. 1987), seemingly to argue that her right to a fair trial has been implicated because of the same alleged prosecutorial

ast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. Aside from

r specified what "fundamental right" the Government allegedly violated nor provided legal authority supporting her claim. She cites United States v. Valentine, 820 F.2d 565, 570 (2d Cir. 1987), seemingly to argue that her right to a fair trial has been implicated because of the same alleged prosecutorial

ast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. Aside from

125 United States v. Turoff, 853 F.2d 1037 (2d Cir. 1988) 138 United States v. Urena, 989 F. Supp. 2d 253 (S.D.N.Y. 2013) 23 United States v. Valentine, 820 F.2d 565 (2d Cir. 1987) 107, 108 United States v. Valona, 834 F.2d 1334 (7th Cir. 1987) 45 United States v. Vickers, 708 F. App'x 732 (2d

bpoenas and Ex Pane Applications for Materials SOW- after opening t mment identified possible victims and their counsel trroiigh ich ina Boies Schiller. (Def. Mem. 3, Ex. E at 2-3). SDNY first cont oies Schiller about its investigation on or about December 18, 2018. Shortly thereafter, in oar Dec

r specified what "fundamental right" the Government allegedly violated nor provided legal authority supporting her claim. She cites United States v. Valentine, 820 F.2d 565, 570 (2d Cir. 1987), seemingly to argue that her right to a fair trial has been implicated because of the same alleged prosecutorial

t complying with any of the specific procedures or exceptions provided in the [confidentiality] orders." Id. Here, by contrast, ga on in late 0111 Schiller shortly the na in Februan Miran order, Aside from rank speculation loosely premised on an anonymously sourced news report, the defendant offers n

r specified what "fundamental right" the Government allegedly violated nor provided legal authority supporting her claim. She cites United States v. Valentine, 820 F.2d 565, 570 (2d Cir. 1987), seemingly to argue that her right to a fair trial has been implicated because of the same alleged prosecutorial

ast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. Aside from

mas, Debra Fel 7) Thomas, Kelly Appeals) Tribuiani, Robert INTAKE) Turek, Paige DOVE•HrnS)Uilman. Barbara ref. Horn.) Vacirca, Eileen CC P) Valentine, Tim DOVE) Valley, Colons Belle Glade) Vidal, Zelda Fel 5) Vila, Elvia Juv L) Vincent, Ann INVEST) Vincent, Linda (An O) VInck. Sheryl (E

yl (Eco Crime) Santamaria, Michelle (HOM) Satcher, Linda (Appeals) Satcher, Lisa (Fel U) Sauvola, Nicole (Belie Glade) Scharaga, Joan (CAC) Schiller, Gregory (Juv Intake) Seder, Sandra Mall Rm) Selvig, Kenneth (INTAKE) Shepherd, Caroline (CC) Shepherd, Robed Juv Intake) Shepherd, Tonya (I

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

No. S I 03 CR. 987DAB, 2009 WL 1585776 (S.D.N.Y. June 8, 2009) 18 United States v. Rajaratnam, 719 F.3d 139 (2d Cir. 2013) 18 United States v. Valentine, 820 F.2d 565 (2d Ck. 1987) 16 Young v. United States, 481 U.S. 787 (1987) 16 ii EFTA00011454 --- PAGE BREAK --- Other Authorities Norman

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

No. S I 03 CR. 987DAB, 2009 WL 1585776 (S.D.N.Y. June 8, 2009) 18 United States v. Rajaratnam, 719 F.3d 139 (2d Cir. 2013) 18 United States v. Valentine, 820 F.2d 565 (2d Ck. 1987) 16 Young v. United States, 481 U.S. 787 (1987) 16 ii EFTA00029079 --- PAGE BREAK --- Other Authorities Norman

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