Epstein Secrets

acking device" for purposes of Rule 41 where used to collect location data); In re Application, 2009 WL 159187, at *5-'1'6 (S.D.N.Y. Jan.13, 2009) (McMahon, J.) (same). 3 See 18 U.S.C. § 3121 (prohibiting use of pen register or trap and trace device without an order under the pen register statute); 312

falls within § 2703(c)(1)); accord, e.g., United States v. Caraballo, 963 F. Supp. 2d 341, 361 (D.Vt. 2013); In re Order, 632 F. Supp. 2d 202, 207 (E.D.N.Y. 2008); In re Application, 405 F. Supp. 2d 435, 444-45 (S.D.N.Y. 2005). But see In re Application, 849 F. Supp. 2d 526, 574 (D.Md. 2011) (rejecting

, in violation of 18 U.S.C. § 2423(a); and perjury, in violation of 18 U.S.C. § 1623 (the "Subject Offenses"). 8. On June 29, 2020, a grand jury in the Southern District of New York returned an indictment charging GHISLAINE MAXWELL with the Subject Offenses. The Indictment charging MAXWELL is attached as Exhibit A hereto (the "

on and Pen Register Information APPLICATION Mag. The United States of America, by its attorney, Audrey Strauss, Acting United States Attorney for the Southern District of New York, Assistant United States Attorney, of counsel, respectfully requests that the Court issue the accompanying proposed Warrants and Orders for prospe

acking device" for purposes of Rule 41 where used to collect location data); In re Application, 2009 WL 159187, at *5-'1'6 (S.D.N.Y. Jan.13, 2009) (McMahon, J.) (same). 3 See 18 U.S.C. § 3121 (prohibiting use of pen register or trap and trace device without an order under the pen register statute); 312

falls within § 2703(c)(1)); accord, e.g., United States v. Caraballo, 963 F. Supp. 2d 341, 361 (D.Vt. 2013); In re Order, 632 F. Supp. 2d 202, 207 (E.D.N.Y. 2008); In re Application, 405 F. Supp. 2d 435, 444-45 (S.D.N.Y. 2005). But see In re Application, 849 F. Supp. 2d 526, 574 (D.Md. 2011) (rejecting

for the Sep phern District of New York charges that four l IRR employees fif retirees ... 34 mins ago Law.com SEIM' Trials Delayed Through Feb. 12 McMahon Says I New ... The chiefjudge of the U.S. District Court for the Southern District of New York has extended the court's suspension of jury trials thr

yees fif retirees ... 34 mins ago Law.com SEIM' Trials Delayed Through Feb. 12 McMahon Says I New ... The chiefjudge of the U.S. District Court for the Southern District of New York has extended the court's suspension of jury trials through Feb. 1 month ago Emtlusinessiteclge fund_hatinderstleadigtullyin_tletmaniklarcus-tiedcas

e defendants engaged in this conduct not for the love of the sport, and certainly not out of concern for the horses, but for money," US Attorney for the Southern District of New York Geoffrey Berman said Monday. "And it was the racehorses that paid the price for the defendants' unbridled greed." Prosecutors alleged the internati

o anyone who recently traveled to countries that are hardest hit by the virus or those who have come into contact with it. In an order, Chief Judge Colleen McMahon said the ban applies to anyone who has traveled to China, South Korea, Japan, Italy or Iran in the past 14 days. Also banned are people who live wit

voiding the virus altogether. "Anyone attempting to enter in violation of these protocols will be denied entry by a court security officer," Judge McMahon wrote. She added that the restrictions would "remain in place temporarily until it is determined to be safe to remove them." 20 EFTA00014262

e defendants engaged in this conduct not for the love of the sport, and certainly not out of concern for the horses, but for money," US Attorney for the Southern District of New York Geoffrey Berman said Monday. "And it was the racehorses that paid the price for the defendants' unbridled greed." Prosecutors alleged the internati

o anyone who recently traveled to countries that are hardest hit by the virus or those who have come into contact with it. In an order, Chief Judge Colleen McMahon said the ban applies to anyone who has traveled to China, South Korea, Japan, Italy or Iran in the past 14 days. Also banned are people who live wit

voiding the virus altogether. "Anyone attempting to enter in violation of these protocols will be denied entry by a court security officer," Judge McMahon wrote. She added that the restrictions would "remain in place temporarily until it is determined to be safe to remove them." 20 EFTA00014282

or Cellphone Location and Pen Register Information The United States of America, by its attorney, Audrey Strauss, Acting United States Attorney for the Southern District of New York, Assistant United States Attorney, of counsel, respectfully requests that the Court issue the accompanying proposed Second Warrant and Order for p

tracking device" for purposes of Rule 41 where used to collect location data); In re Application, 2009 WL 159187, at *5 *6 (S.D.N.Y. Jan.13, 2009) (McMahon, J.) (same). 3 See 18 U.S.C. § 3121 (prohibiting use of pen register or trap and trace device without an order under the pen register statute); 312

imum, this Court Should Order a Hearing at which Maxwell May Inquire into the Circumstances Surrounding the Government's Misrepresentation to Judge McMahon 26 Conclusion 27 Certificate of Service 29 EFTA00028930 --- PAGE BREAK --- Table of Authorities Cases Abdell v. City of New York, No. 05 C

on first began. None of these statements by AUSA to Judge McMahon were true. As described above, attorneys pressed the U.S. Attorney's Office for the Southern District of New York to investigate and prosecute Epstein and Maxwell. Ex. J. Then, two months after the meeting with AUSA attorneys told Judge Sweet—who was presiding

epositions 4 C. The Settlement And Boles 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 Identical Gambit By The Government 10 ARGUMENT 11 A. Pursuant To Its Inherent Power, This Court Sho

ed by Boies Schiller in a defamation action it filed against Maxwell on behalf of one of the firm's clients. v. Marvell, Case No. 15-cv-7433 (LAP) (S.D.N.Y). A Protective Order entered in that case prohibited the parties and their lawyers from sharing confidential discovery material (including the two

imum, this Court Should Order a Hearing at which Maxwell May Inquire into the Circumstances Surrounding the Government's Misrepresentation to Judge McMahon 26 Conclusion 27 Certificate of Service 29 EFTA00029101 --- PAGE BREAK --- Table of Authorities Cases Abdell v. City of New York, No. 05 C

on first began. None of these statements by AUSA to Judge McMahon were true. As described above, attorneys pressed the U.S. Attorney's Office for the Southern District of New York to investigate and prosecute Epstein and Maxwell. Ex. J. Then, two months after the meeting with AUSA attorneys told Judge Sweet—who was presiding

epositions 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 Identical Gambit By The Government 10 ARGUMENT 11 A. Pursuant To Its Inherent Power, This Court Sho

ed by Boies Schiller in a defamation action it filed against Maxwell on behalf of one of the firm's clients. v. Marvell, Case No. 15-cv-7433 (LAP) (S.D.N.Y). A Protective Order entered in that case prohibited the parties and their lawyers from sharing confidential discovery material (including the two