Epstein Secrets

a claim which is barred by the statute of limitations; (c) fails to allege personal jurisdiction over Intervenors; and (d) improperly lays venue in the Southern District of New York. The FAC alleges a brief adult relationship between Jane Doe and Mr. Epstein beginning in October 2006. Jane Doe describes herself as a

rder 1. The Court Has Broad Discretion to Modify the Protective Order This Court has broad power to modify existing protective orders. S.E.C. v. TheStreetcom, 273 F.3d 222, 231 (2d Cir. 2001). Before modifying a protective order, the Court must first determine if the parties to the original order "reasona

cedure grant the Court authority to strike surplusage from an indictment, see Fed. R. Crim. P. 7(d), lijt has long been the policy of courts within the Southern District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez,

such pre-existing documents not created in reliance on a protective order,which do not trigger the Martindell presumption in the Second Circuit, see TheStreetcom, 273 F.3d at 234-235; Davis, 702 F.2d at 422. Maxwell's arguments also do not extend to ositions, why 8I EFTA00100048 2. Maxwell's Fourth Amen

w, the motions should be denied in their entirety. First, the non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida is entirely irrelevant to this case, and the defendant's motion fails as a matter of law. Second, the indictment is timely under 18 U.S.C

ntobello v. United States, No. 94 Cr. (RPP), 1998 WL 113950 (S.D.N.Y. Mar. 13, 1998) 21 Sch. Dist. No. 7, 167 F.3d 784 (2d Cir. 1999) 61 SEC v. TheStreetcom, 273 F.3d 222 (2d Cir. 2001) 109, 113 viii EFTA00103007 Silver, 15 Cr. 93 (VEC) 275 Skelos, 15 Cr. 317 (KMW) 275 Smith v. Maryland, 442