Epstein Secrets

Government Exhibit 52 because Mr. , a former employee, purportedly removed the document from the property before Employee-1 began working for Mr. Epstein. The parties are FURTHER ORDERED to file any proposed redactions to the motion papers on the public docket on or before November 22, 2021, justifyin

the property before Employee-1 began working for Mr. Epstein. The parties are FURTHER ORDERED to file any prop

r before November 22, 2021, justifying any requested redactions by reference to the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). EFTA00014649

pted suicide of his former and now-late cellmate Jeffrey Epstein. Id. at 1-2. The Government submitted a s

document has been historically available (the "experience" prong) and would be valuable to the process in question (the "logic" prong). Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119-20 (2d Cir. 2006). The weight of the common law presumption turns on "the role of the material at issue in the exercise of Artic

ors to seek death penalty for ex-cop in quadruple homicide, New York Post (Mar. 21, 2019) httos://bitivam7aloL. See, e.g., William K. Rashbaum et al.,Jeffrey Epstein Is Found Injured in Jail Cell, New York Times (July 25, 2019) htips://nyti.ms/2kbOXbe. 9 See, e.g., Emily Saul, Jail guards threatening former Epste

e Lugosch, 435 F.3d at 124. 5 EFTA00017099 --- PAGE BREAK --- charges against him and the prosecutors' decision to seek the death penalty.? Mr. Epstein's attempted suicide, which occurred while Mr. Tartaglione was his cellmate, roused even greater interest in his case! Put simply, the public is wat

, Denver, CO 80203, By: Laura A. Menninger, Esq., Jeffrey S. Pagliuca, Esq., Ty Gee, Esq. Counsel for Int

British tabloids, described Maxwell's alleged role as someone who recruited or facilitated the recruitment of young females for sexual activity with Jeffrey Epstein ("Epstein"), that she, M, had been interviewed by the Federal Bureau of Investigation ("FBI") in 2011, and that she had discussed Maxwell's involv

described Maxwell's alleged role as someone who recruited or facilitated the recruitment of young females for sexual activity with Jeffrey Epstein ("Epstein"), that she, M, had been interviewed by the Federal Bureau of Investigation ("FBI") in 2011, and that she had discussed Maxwell's involvement in t

s." 191 1101 1111Whether discovery or trial, "a court must first conclude that the documents at issue are indeed `judicial documents.' " Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119 (2d Cir. WESTLAW © 2018 Thomson Reuters. No claim to original U.S. Government Works. 21 EFTA00020561 --- PAGE BREAK --- v. M

The Court's decision to adopt the Government's proposed redactions is guided by the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Under this test, the Court must: (i) determine whether the documents in question are "judicial documents;" (ii) assess

ing factual information: I. Grand jury subpoenas were issued to an entity ("Recipient") after the Government opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. The Recipient concluded that it could not turn over materials responsive to the grand jury subpoena absent a

t opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. The Recipi

overnment opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. Th

The Court's decision to adopt the Government's proposed redactions is guided by the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Under this test, the Court must: (i) determine whether the documents in question are "judicial documents;" (ii) assess

ing factual information: I. Grand jury subpoenas were issued to an entity ("Recipient") after the Government opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. The Recipient concluded that it could not turn over materials responsive to the grand jury subpoena absent a

t opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. The Recipi

overnment opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. Th

Exhibit B, which is Dr. Hall's evaluation of Minor Victim-4, in accordance with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although this brief and the attached exhibit are judicial documents subject to the common law presumption of access,

will be contradicted by statements she made to Dr. Hall. And to be clear, Minor Victim-4's expected testimony about the defendant's involvement in Epstein's scheme is not inconsistent with the fact that Minor Victim-4 did not describe those instances to Dr. Hall. "It is well settled that for two statem

to propose any redactions to the Courts Opinion and Order and to justify those redactions by reference tothe Second Circuits decision in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110(2d Cir. 2006). After determining which, if any, portions of the Opinion and Order should be redacted, the Court will file the Opinion

-AJN-1 Notice has been electronically mailed to: Jeffrey S. Pagliuca Laura A. Menninger Bobbi C Stemhein