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al settlement agreement. Early in the civil litigation, one of the attorneys representing approached an Assistant United States Attorney (AUSA) in the Southern District of New York and requested a No. EFTA00106039 Case 1:20-cr-00330-AJN Document 307 Filed 06/25/21 Page 2 of 21 meeting to provide the Government i
. No. 134-1 ¶ 13. A court may (as here) unseal documents covered by a civil protective order in the public interest. See Brown, 929 F.3d at 47; v. Marvell, 827 F. App'x 144, 145 (2d Cir. 2020); Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 126 (2d Cir. 2006). Civil litigants have neither a reasonab
ot a functioning contact.'" The woman (now using the pseudonym "Jane Doe) filed a new lawsuit in June 2016, this time in the U.S. District Court for the Southern District of New York. She excluded some of her previous accusations, such OS that Trump threw money for an abortion at her and that he called Epstein a -Jew
townhouse a few blocks away. Epstein Is frequently seen around team with a hay- at coin* yang; women but Mar hat been no boldfaced name to replace Marvell. "You 'nay read about Jeffrey in these:ail column, but there Is mud: Rant to him than that; mys Jeffrey-7. lee& of tlw private *quite rem Leeds Weld
o join the case, Dershowitz personally helped to negotiate the non-prosecution agreement (NPA) at issue in this case, which bars his prosecution in the Southern District of Florida as a "potential co-conspirator of Epstein." DE 280 at 4 (quoting NPA at 5). The Court has previously allowed Epstein to prospectively int
ked questions about his sexual abuse of young girls, including Jane Doe No. I, Jane Doe No. 2, and Jane Doe No. 3. See generally Exhibit 16 at 1-7. Marvell. In 2009, undersigned counsel (Brad Edwards) served Ghislaine Maxwell with a subpoena for a deposition in a civil case against Jeffrey Epstein. Afte
ein and Maxwell!' Then, after Maxwell's two depositions, David Boies himself apparently approached the government in the summer of 2016, asking "if the Southern District would consider charging Maxwell with perjury." Brown, supra n.2. Said Mr. Boies: "We were saying to anyone who would listen: We've got clients who
or who was deposed in the case. The prosecutor defended the subpoena's breadth—which sought all "copies of discovery and related materials" irMv. Marvell—on the ground that the government simply had too little knowledge of what was in the law firm's files to craft a more narrowly tailored subpoena:
Entities connected to both the Southern District and Marvell

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
Prince Andrew
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
New York
LOCATION
Geoffrey S. Berman
PERSONLeon Black
PERSON
Alan Dershowitz
PERSON
Virginia Giuffre
PERSON
Scarlett Johansson
PERSON
Donald Trump
PERSONMaria Farmer
PERSON
Julie K. Brown
PERSON
Bill Clinton
PERSONGerald Lefcourt
PERSON
Palm Beach County
LOCATION
U.S. Virgin Islands
LOCATION