Epstein Secrets

ghted. Document Request No. 28: All documents relating to your travel from the period of 2000 —present, including but not limited to, any travel on Jeffrey Epstein's planes, commercial flights, helicopters and records indicating passengers traveling with you, hotel records, and credit card receipts. It is not cl

e motion to strike provides specific facts in support of the plaintiffs allegations that she was recruited an enticed into performing sex acts with Epstein as part of a larger enterprise to provide Epstein with young females for sex, in which each defendant allegedly played a specific role. The defenda

, Rm 430 New York, NY 10007 Re: Jane Doe 43 v. Jeffrey Epstein, et at, Case No.: 17-cv-00616 (JGK) — Le

uch terms as "entity" as appropriate, given that Mr. Epstein has invoked his Fifth Amendment rights rather tha

f Law at the University of Utah 383 S. University St. Salt Lake Cit UT 84112 Tele hone: December 13, 2018 VIA CM/ECF Honorable Magistrate Judge Sarah Netburn United States District Court Thurgood Marshall Courthouse 40 Foley Square, Rm 430 New York, NY 10007 Re: Jane Doe 43 v. Jeffrey Epstein, et at,

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 Ap

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

The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 February 28, 2019 TO BE FILED UNDER SEAL VIA EMAIL The Honorable Sarah Netburn United States District Court Southern District of New York United States Courthouse New York, New York 10007 Re: In re Application to Unseal Ci

lieving Boies Schiller & Flexner LLP (the "Law Finn") of its obligations under the protective order issued on November 29, 2018, in Jane Doe 43 v. Jeffrey Epstein. et al. I7-CV-616 (IGK) (SN) (S.D.N.Y.). The purpose of such order is to permit the Law Firm to comply with a grand jury subpoena and provide mate

r issued on November 29, 2018, in Jane Doe 43 v. Jeffrey Epstein. et al. I7-CV-616 (IGK) (SN) (S.D.N.Y.).

New York. IN RE APPLICATION TO UNSEAL CIVIL DISCOVERY MATERIALS, USAO Reference No. 2o18Ro1618. 19-MC-00179 (SN) Filed 03/24/2021 SEALED ORDER SARAH NETBURN United States Magistrate Judge *1 The United States Attorney for the Southern District of New York has moved, pursuant to the All Writs Act, Title

promote the settlement of disputes."). *3 In response to an identical application seeking to modify a protective order in a different case between Epstein and an alleged victim, another judge in this District has reached a different conclusion. That judge found that Epstein's reliance on the protecti

ined with an ongoing criminal grand jury investigation, which, despite significant coverage in the media in connection with charges brought against Jeffrey Epstein and Ghislaine Maxwell, nevertheless continues to include matters not publicly known or confirmed through public filings or Government statements. T

connection with charges brought against Jeffrey Epstein and Ghislaine Maxwell, nevertheless continues to

media in connection with charges brought against Jeffrey Epstein and Ghislaine Maxwell, nevertheless conti

ork The Silvio J. Moto Building One Saint Andrew's Plaza New York. New York 10007 July 22, 2020 TO BE FILED UNDER SEAL VIA EMAIL The Honorable Sarah Netburn United States District Court Southern District of New York United States Courthouse New York, New York 10007 Re: In re Application to Unseal Ci

From: ' To: ' Subject: RE: Jane Doe 43 v. Epstein, et al., 17 Civ. 616 (JGK)(SN) Date: Thu, 14 Mar 2019 18:56:17 +0000 Importance: Normal Attachments: 2019-03-14, JE,_unsealing_proposed_orderias_s

ndering if you have a Word version of the Sealed Order that you can email? Let me know when you get the chance. Tha n Courtroom Deputy to the Hon. Sarah Netburn United States District Court Southern District of New York 40 Foley Square New York, NY 10007 EFTA00019482

York, New lark 10007 August 12, 2020 VIA EMAIL Jeffrey S. Pagliuca, Esq. Haddon, Morgan and Foreman, P.

g Materials is appropriate because they pertain to an ongoing grand jury investigation and because Chief Judge Colleen McMahon and Magistrate Judge Sarah Netburn have ordered that the Unsealing Materials remain under seal. The only exceptions to those sealing orders are the permission contained in Chief Judge