Epstein Secrets

nk Nat. Ass 'n v. PHL Variable Ins. Co., No. 12 CIV. 6811 CM JCF, 2012 WL 5395249 (S.D.N.Y. Nov. 5, 2012) 2 iii EFTA00100289 Other Authorities Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 11 Rules

A: Motion to Compel Plaintiff to Disclose Alleged "On-going Criminal Investigations by Law Enforcement" or, In the Alternative, to Stay Proceedings. Giuffre v. Maxwell, No. 15-cv- 07433-RWS, Apr. 18, 2016 EXHIBIT B: Giuffre v. Maxwell, No. 15-cv-07433-RWS, Transcript, Apr. 21, 2016 EFTA00100291 Ghislaine Maxwell

n District of New York against Maxwell or Epstein's estate, the government deliberately chose not to intervene in the on-going unsealing process in Giuffre v. Maxwell. In the only other active SDNY case against Epstein, Doe v. Indyke, No. 20-cv-484-JLIC, the government intervened and moved to stay discovery, sayi

e defense attorneys' alleged efforts to "pique" the Government's interest "in a second meeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020,

on in ordering the unsealing of the deposition materials and that Maxwell's interests outweighed the public's interests in access to the materials. Giuffre v. Maxwell, No. 20-2413 (2d Cir.), (Dkt. No. 140-1 at 2). On October 19, 2020, the Second Circuit found that Judge Preska "correctly held that the deposition m

on a motion to dismiss without the benefit of the full factual record. The motion should be denied. allegations that were central to the dispute in Giuffre v. Maxwell." (Def. Mot. 4, Ex. I at 7:3-6.) (The last colloquy has been unsealed except for Minor Victim-2's name. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1).)

e defense attorneys' alleged efforts to "pique" the Government's interest "in a second meeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020,

on in ordering the unsealing of the deposition materials and that Maxwell's interests outweighed the public's interests in access to the materials. Giuffre v. Maxwell, No. 20-2413 (2d Cir.), (Dkt. No. 140-1 at 2). On October 19, 2020, the Second Circuit found that Judge Preska "correctly held that the deposition m

on a motion to dismiss without the benefit of the full factual record. The motion should be denied. allegations that were central to the dispute in Giuffre v. Maxwell." (Def. Mot. 4, Ex. I at 7:3-6.) (The last colloquy has been unsealed except for Minor Victim-2's name. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1).)

urces, "a second meeting occurred." However, the Article cites another anonymous source as "insist[ing] [a second meeting] never happened." 36 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020,

ess attaches, and did not abuse its discretion in rejecting Maxwell's meritless arguments that her interests superseded the presumption of access." Giuffre v. Maxwell, No. 20-2413 (2d Cir.) (Dkt. No. 140-1 at 3).43 On October 22, 2020, the defendant's April 2016 deposition was publicly filed. (See 15 Civ. 7433 (L

Count Six, stating that the "testimony is .. . far afield from the sex trafficking and sexual abuse allegations that were central to the dispute in Giuffre v. Maxwell." (Def. Mot. 4, Ex. I at 7:3-6.) (The last colloquy has been unsealed except for Minor Victim-2's name. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1).)