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United States, 165 U.S. 257 (1897) 296 Russell v. United States, 369 U.S. 749 (1962) 229 Rutenberg v. United States, 245 U.S. 480 (1918) 292 Salinas v. United States, 522 U.S. 52 (1997) 245 Santobello v. United States, No. 94 Cr. (RPP), 1998 WL 113950 (S.D.N.Y. Mar. 13, 1998) 21 Sch. Dist. N
as aware, Doe v. Indyke was the "lone case in this District that has not yet been either resolved or stayed at this point. . . In 23 In particular, Giuffre v. Maxwell was resolved in 2017 and the determination of what material should remain sealed remains the only open issue. Accordingly, there is no more discover
by a stay in the Doe case because the outcome of the criminal case could resolve disputed issues in the Doe case. Such concerns are not present in Giuffre v. Maxwell. 57 EFTA00077689 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine M
t that argument ignores a fundamental tenet of conspiracy law. It is axiomatic that a conspiracy does not require a completed substantive crime. See Salinas v. United States, 522 U.S. 52, 65 (1997) ("It is elementary that a conspiracy may exist and be punished whether or not the substantive crime ensure
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).)
United States, 165 U.S. 257 (1897) 296 Russell v. United States, 369 U.S. 749 (1962) 229 Rutenberg v. United States, 245 U.S. 480 (1918) 292 Salinas v. United States, 522 U.S. 52 (1997) 245 Santobello v. United States, No. 94 Cr. (RPP), 1998 WL 113950 (S.D.N.Y. Mar. 13, 1998) 21 Sch. Dist. N
as aware, Doe v. Indyke was the "lone case in this District that has not yet been either resolved or stayed at this point. . . In 23 In particular, Giuffre v. Maxwell was resolved in 2017 and the determination of what material should remain sealed remains the only open issue. Accordingly, there is no more discover
by a stay in the Doe case because the outcome of the criminal case could resolve disputed issues in the Doe case. Such concerns are not present in Giuffre v. Maxwell. 57 EFTA00039504 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine M
t that argument ignores a fundamental tenet of conspiracy law. It is axiomatic that a conspiracy does not require a completed substantive crime. See Salinas v. United States, 522 U.S. 52, 65 (1997) ("It is elementary that a conspiracy may exist and be punished whether or not the substantive crime ensure
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).)
United States, 165 U.S. 257 (1897) 203 Russell v. United States, 369 U.S. 749 (1962) 151 Rutenberg v. United States, 245 U.S. 480 (1918) 200 Salinas v. United States, 522 U.S. 52 (1997) 161 Santobello v. United States, No. 94 Cr. (RPP), 1998 WL 113950 (S.D.N.Y. Mar. 13, 1998) 18 Sch. Dist. N
stayed at this point. . . In particular, this matter appears to be the only remaining active civil case in this District in which 23 In particular, Giuffre v. Maxwell was resolved in 2017 and the determination of what material should remain sealed remains the only open issue. Accordingly, there is no more discover
by a stay in the Doe case because the outcome of the criminal case could resolve disputed issues in the Doe case. Such concerns are not present in Giuffre v. Maxwell. 57 EFTA00095149 claims against Ghislaine Maxwell have been asserted." (20 Civ. 484 (DCF) (JGK), Dkt. No. 80 at 2). The defendant's baseless con
t that argument ignores a fundamental tenet of conspiracy law. It is axiomatic that a conspiracy does not require a completed substantive crime. See Salinas v. United States, 522 U.S. 52, 65 (1997) ("It is elementary that a conspiracy may exist and be punished whether or not the substantive crime ensure
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).)
Entities connected to both Salinas and Giuffre v. Maxwell

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSON
United States
LOCATION
Julie K. Brown
PERSON
Virginia Giuffre
PERSONMaria Farmer
PERSONthe Southern District
LOCATION
George Mitchell
PERSON
Bradley Edwards
PERSON
Minnesota
LOCATION
Scarlett Johansson
PERSON
Supreme Court
ORGANIZATION
Bill Richardson
PERSONWerner
PERSONJane Doe
PERSON
Michael Jackson
PERSONSweet
PERSON
Colorado
LOCATION
Prince Andrew
PERSON
Adriana Ross
PERSON