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me, in violation of 18 U.S.C. §§ 2423 and 2. Counts Five and Six charge the defendant with perjury, in violation of 18 U.S.C. § 1623.i ARGUMENT I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA"
in illegal sex acts, and aiding and abetting the same, in violation 18 U.S.C. §§ 2422 and 2. Count Three charges the defendant with conspiring with Epstein and others to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371. Count Four charges the defendant with transporti
NARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant
f America Assistant United States Attorneys - Of Counsel - EFTA00102999 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case 3 A. The NPA Does Not Bind the Southern District of New York 4 1. The Text of the Agreement
n ongoing campaign to vilify Ms. Maxwell." (Def. Mot. 7 at 16). She again cites the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obtain materials from the civil litigation. (Id.). Leaving aside the fact that, as set forth in Section IV, the Government obtained such mate
me, in violation of 18 U.S.C. §§ 2423 and 2. Counts Five and Six charge the defendant with perjury, in violation of 18 U.S.C. § 1623.1 ARGUMENT I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA"
in illegal sex acts, and aiding and abetting the same, in violation 18 U.S.C. §§ 2422 and 2. Count Three charges the defendant with conspiring with Epstein and others to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371. Count Four charges the defendant with transporti
NARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant
f America Assistant United States Attorneys - Of Counsel - EFTA00077606 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case 3 A. The NPA Does Not Bind the Southern District of New York 4 1. The Text of the Agreement
n ongoing campaign to vilify Ms. Maxwell." (Def. Mot. 7 at 16). She again cites the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obtain materials from the Giuffre civil litigation. (Id.). Leaving aside the fact that, as set forth in Section IV, the Government obtained su
me, in violation of 18 U.S.C. §§ 2423 and 2. Counts Five and Six charge the defendant with perjury, in violation of 18 U.S.C. § 1623.1 ARGUMENT I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA"
in illegal sex acts, and aiding and abetting the same, in violation 18 U.S.C. §§ 2422 and 2. Count Three charges the defendant with conspiring with Epstein and others to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371. Count Four charges the defendant with transporti
NARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant
f America Assistant United States Attorneys - Of Counsel - EFTA00039421 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case 3 A. The NPA Does Not Bind the Southern District of New York 4 1. The Text of the Agreement
n ongoing campaign to vilify Ms. Maxwell." (Def. Mot. 7 at 16). She again cites the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obtain materials from the Giuffre civil litigation. (Id.). Leaving aside the fact that, as set forth in Section IV, the Government obtained su
LES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
Page: EFTA00018997 →T OF HER MOTION UNDER THE FOURTH AMENDMENT, MARTINDELL, AND THE FIFTH AMENDMENT TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S SUBPOENA TO BOLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203
Page: EFTA00018997 →N.Y. Nov. 5, 2012) 2 iii EFTA00018999 --- PAGE BREAK --- 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 Fed. R. Civ. P. 24(b) 4 Fed. R. Civ. P. 26(c) 13 Fed. R. Cr
Page: EFTA00019000 →is this: The defamation case should have been extremely narrow, but Boies Schiller transformed it into something much broader—a proxy prosecution of Epstein and Maxwell for allegedly trafficking and abusing Giuffre, which then compelled Maxwell, over objection, to answer irrelevant and highly prejudicia
Page: EFTA00019004 →From: To: aNYS)" Subject: RE: Boles Schiller--Jeffrey Epstein Supposedly Sealed Order Date: Tue, 30 Mar 2021 14:34:50 +0000 This is a 2019 order that was recently unsealed. We made an application to modify a p
Page: EFTA00019095 →To: aNYS)" Subject: RE: Boles Schiller--Jeffrey Epstein Supposedly Sealed Order Date: Tue, 30 Mar 2021 1
Page: EFTA00019095 →From: To: aNYS)" Subject: RE: Boles Schiller--Jeffrey Epstein Supposedly Sealed Order Date: Tue, 30 Ma
Page: EFTA00019095 →From: To: aNYS)" Subject: RE: Boles Schiller--Jeffrey Epstein Supposedly Sealed Order Date: Tue, 30 Mar 2021 14:34:50 +0000 This is a 2019 order that was recently unsealed. We made an applicat
Page: EFTA00019095 →IIM> To: ri " aNIMIN>, Subject: Boles Schiller--Jeffrey Epstein Supposedly Sealed Order Date: Tue, 30 Ma
Page: EFTA00029950 →From: (USANYS)" aMMIIM> To: ri " aNIMIN>, Subject: Boles Schiller--Jeffrey Epstein Supposedly Sealed Order Date: Tue, 30 Mar 2021 14:20:31 +0000 Attachments: IN_RE_APPLICATION_TO_UNSEAL_CI VIL_DISCOVERY_MATERIALS_USAO_Refe rence_
Page: EFTA00029950 →: ri " aNIMIN>, Subject: Boles Schiller--Jeffrey Epstein Supposedly Sealed Order Date: Tue, 30 Mar 2021 1
Page: EFTA00029950 →From: (USANYS)" aMMIIM> To: ri " aNIMIN>, Subject: Boles Schiller--Jeffrey Epstein Supposedly Sealed Order Date: Tue, 30 Mar 2021 14:20:31 +0000 Attachments: IN_RE_APPLICATION_TO_UNSEAL_CI VIL_DISCOVERY_MATERIALS_
Page: EFTA00029950 →k Release The Palm Beach County Sheriffs Office announced on Friday an internal investigation into the Florida departments supervision of financier Jeffrey Epstein when he was jailed there a decade ago on sex crime charges, after a lawyer for some of Epstein's alleged victims implied the accused child rapist h
Florida departments supervision of financier Jeffrey Epstein when he was jailed there a decade ago on sex crime charges, after a lawyer for some of Epstein's alleged victims implied the accused child rapist had abused the privileges of his work release. Read full article » SECURITIES Judge Won't Let
the Florida departments supervision of financier Jeffrey Epstein when he was jailed there a decade ago on
Say Podcast Listen to our new podcast here LAW FIRMS Addleshaw Goddard Akin Gump Allen & Overy Arnold & Porter Ashurst LLP Barrett & Singal Boles Schiller Cahill Gordon Caplin & Drysdale Cadton Fields Casner & Edwards Covington & Burling Dechert Drinker Biddle Duane Morris Edwards Pottinger Ev
OW THESE THINGS YOU SEE. FYI DS I would also like an investigation done on how many times =M entered the UK fmm when she first started working for Epstein. You see we both know-_ went to the UK and trafficked to the UK. Now why do I want you to investigate this?? Because the plea barging does NOT EX
against James Marsh, Jennifer Freeman, Robert Lewis, Brad Edwards and Britney. I would also like them to pay the my full settlement!! DC as long as Boles Schiller trades in the UK which it does AS THEY HAVE AN OFFICE IN LONDON IT IS IN YOUR AREA BY THE WAY. DC Stan Pottinger openly hit on me repeatedly. He tr
An Identical Gambit By The Government 10 ARGUMENT 11 A. Pursuant To Its Inherent Power, This Court Should Suppress The Evidence Obtained From Boles Schiller, And Dismiss Counts Five And Six, Which Are The Fruits Of That Evidence 11 I. The role of protective orders in civil litigation 11 2. The go
Page: EFTA00029078 →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
Page: EFTA00029080 →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
Page: EFTA00029084 →Entities connected to both Jeffrey Epstein and Boles Schiller

Lesley Groff
PERSONDarren Indyke
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
John F. Kennedy
PERSON
George Mitchell
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Stephen Hawking
PERSON
Sarah Kellen
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSONMartin Weinberg
PERSON
Julie K. Brown
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATION
Reid Weingarten
PERSON