Epstein Secrets

r, "An Appeal to Lillian Hellman and Mary McCarthy," 5/11/80 New York Times 2 Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 9 Rules Fed. R. Civ. P. 1 12 Constitutional Provisions U.S. CONST. am

ing a time- honored if unfortunate litigation tactic, her lawyers at Boies Schiller therefore sought to turn the lawsuit into a proxy prosecution of Epstein. Not surprisingly, discovery in the case was bitter, hard-fought, and wide-ranging. It spanned more than a year and included large document product

replied, "I don't know what you're talking about." And when asked to "[I]ist all the people under the age of 18 that you interacted with at any of Jeffrey's properties," Maxwell responded, "I'm not aware of anybody that I interacted with, other than obviously I who was 17 at this point." Count Five o

ony when she testified during her July 2016 deposition that: (1) she could not recall whether sex toys or devices were used in sexual activities at Epstein's Palm Beach house; (2) she did not know whether Epstein possessed sex toys or devices used in sexual activities; (3) she wasn't aware that Epstein w

17 WL 2834260 (E.D. Pa. June 30, 2017) 17 Manhattan Review LLC v. Ytni, 16 Civ. 0102 (LAK) (JCF), 2017 WL 11455317 (S.D.N.Y. Sept. 21, 2017) 17 Martindeli v. Intl Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979) 12, 13 S.E.C. v. TheStreet.Com, 273 F.3d 222 (2d Cir. 2001) 12 Stewart v. Hudson Hall LLC

r to unseal discovery materials in the possession of Boies Schiller & Flexner LLP (the "Application"), in connection with the matter Jane Doe 43 v. Epstein, et al. ("Jane Doe"), 17 Civ. 616 (JGK) (SN) (the "Litigation"), a copy of which is attached hereto as Exhibit A. Background As described in the A

n of copies of discovery and related materials related to the Litigation. The Subpoena was validly issued pursuant to an ongoing investigation into Jeffrey Epstein and others, for possible violations of Title 18, United States Code, Sections 1591 and 1594(c) (unlawfully trafficking minors) and Section 2422(b)

issued pursuant to an ongoing investigation into Jeffrey Epstein and others, for possible violations of T

s the materials at issue here appear not to be of the sort that ordinarily would provide protection against Government investigation. See 3 To read Martindeli more broadly would not only be contrary to the opinion itself, as described above, but would risk rendering that opinion in even further conflict wi

n of copies of discovery and related materials related to the Litigation. The Subpoena was validly issued pursuant to an ongoing investigation into Jeffrey Epstein and others, for possible violations of Title 18, United States Code, Sections 1591 and 1594(c) (unlawfully trafficking minors) and Section 2422(b)

ce and scope of the Investigation in this district is not publicly known. While counsel for certain victims are aware of the Investigation, neither Epstein nor other subjects of the investigation are believed to be similarly aware. Accordingly, the ordinary exercise of grand July power to "subpoena witn

issued pursuant to an ongoing investigation into Jeffrey Epstein and others, for possible violations of T

s the materials at issue here appear not to be of the sort that ordinarily would provide protection against Government investigation. See 3 To read Martindeli more broadly would not only be contrary to the opinion itself, as described above, but would risk rendering that opinion in even further conflict wi

the Southern District of New York, and the Attorney General for the U.S. Virgin Islands, that investigations surrounding the alleged conduct of Mr. Epstein survive his death. It is unclear who are witnesses or targets of any investigation. These ongoing investigations are a powerful countervailing inter

es 164 and 230 at This Time. Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN,

nce of Judge Frankel's decision in GAF Corp. v. Eastman Kodak Co., 415 F.Supp. 129 (S.D.N.Y.1976), with which I fully concur.") (footnote omitted). Martindeli was cited with approval in SEC v. TheStreet.com, 273 F.3d 222, 232 (2d Cir. 2001), which was cited with approval in Brown, 929 F.3d at 51 n.40. Not

17 WL 2834260 (E.D. Pa. June 30, 2017) 17 Manhattan Review LLC v. Ytni, 16 Civ. 0102 (LAK) (JCF), 2017 WL 11455317 (S.D.N.Y. Sept. 21, 2017) 17 Martindeli v. Intl Tel. & Tel. Cotp., 594 F.2d 291 (2d Cir. 1979) 12, 13 S.E.C. v. TheStreet.Com, 273 F.3d 222 (2d Cir. 2001) 12 Stewart v. Hudson Hall LLC

r, "An Appeal to Lillian Hellman and Mary McCarthy," 5/11/80 New York Times 2 Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 9 Rules Fed. R. Civ. P. 1 12 Constitutional Provisions U.S. CONST. am

ing a time- honored if unfortunate litigation tactic, her lawyers at Boies Schiller therefore sought to turn the lawsuit into a proxy prosecution of Epstein. Not surprisingly, discovery in the case was bitter, hard-fought, and wide-ranging. It spanned more than a year and included large document product

17 WL 2834260 (E.D. Pa. June 30, 2017) 17 Manhattan Review LLC v. Ytni, 16 Civ. 0102 (LAK) (JCF), 2017 WL 11455317 (S.D.N.Y. Sept. 21, 2017) 17 Martindeli v. Intl Tel. & Tel. Cotp., 594 F.2d 291 (2d Cir. 1979) 12, 13 S.E.C. v. TheStreet.Com, 273 F.3d 222 (2d Cir. 2001) 12 Stewart v. Hudson Hall LLC

r, "An Appeal to Lillian Hellman and Mary McCarthy," 5/11/80 New York Times 2 Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 9 Rules Fed. R. Civ. P. 1 12 Constitutional Provisions U.S. CONST. am

ing a time- honored if unfortunate litigation tactic, her lawyers at Boies Schiller therefore sought to turn the lawsuit into a proxy prosecution of Epstein. Not surprisingly, discovery in the case was bitter, hard-fought, and wide-ranging. It spanned more than a year and included large document product