Epstein Secrets

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

ll compliance.33 (Exs. 8 & 9). Accordingly, the Government applied ex parte and under seal to each relevant court (Judge Sweet and Magistrate Judge Sarah Netbum, respectively) to request that each court modify the respective protective orders to permit compliance with the subpoenas. (Def. Mot. 3, Ex. C). Fo

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

full compliance.33 (Exs. 8 & 9). Accordingly, the Government applied a pate and under seal to each relevant court (Judge Sweet and Magistrate Judge Sarah Netbum, respectively) to request that each court modify the respective protective orders to permit compliance with the subpoenas. (Def. Mot. 3, Ex. C). Fo

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

full compliance.33 (Exs. 8 & 9). Accordingly, the Government applied a pate and under seal to each relevant court (Judge Sweet and Magistrate Judge Sarah Netbum, respectively) to request that each court modify the respective protective orders to permit compliance with the subpoenas. (Def. Mot. 3, Ex. C). Fo

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

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

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

nt maintains that the "Confidential" designation of the Unsealing Materials is appropriate because Chief Judge Colleen McMahon and Magistrate Judge Sarah Netbum have ordered that the Unsealing Materials remain under seal. The only exceptions to those sealing orders are the production of Chief Judge McMahon'

From: ' To: ' Cc: " Subject: RE: Jane Doe 43 v. Epstein, et al., 17 Civ. 616 (JGK)(SN) Date: Tue, 09 Apr 2019 23:06:59 +0000 Importance: Normal Attachments: 2019-04- 09,_JE, Jetterproviding_additional_a

e Sealed Order that you can email? Let me know when you get the chance. Thank you, EFTA00019577 --- PAGE BREAK --- Courtroom Deputy to the Hon. Sarah Netbum United States District Court Southern District of New York 40 Foley Square New York, NY 10007 EFTA00019578