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he Defendant identified five individuals who require notice, but the Subpoena appears to seek personal and confidential information about all of the Epstein victims that BSF represents, which is more than five individuals. Thus, in an abundance of caution, BSF will notify each of the Epstein victims it
Defendant with two counts of jury for lying under oath during a civil deposition in a defamation action brought by when asked if she was aware of Jeffrey Epstein's sex trafficking scheme and whe er s e a ever iven Minor Victim-2 a massage. BSF represents Minor Victim-2 i and but does not represent and has ne
ction brought by when asked if she was aware of Jeffrey Epstein's sex trafficking scheme and whe er s e
Defendant can therefore procure from the Government. Thus, a Rule 17(c) subpoena to BSF for those documents is improper. See, e.g., United States v. Bergstein, No. 16 Cr. 746 (PKC), 2017 WL 6887596, at *5 (S.D.N.Y. Dec. 28, 2017) ("When `many' of the subpoenaed materials are obtainable through the discove
Request 12, which seeks "any" submission to the Epstein Victims' Compensation Program made by BSF, fails
e Government's briefing regardless of standing as part of its duty to ensure that the subpoena meets the requirements of Nixon. See United States v. Bergstein, No. I6-CR-746 (PKC), 2017 WL 6887596, at *3 (S.D.N.Y. Dec. 28, 2017). But ex parte Rule 17(c) subpoenas are possible in some circumstances if just
Request 12, which seeks "any" submission to the Epstein Victims' Compensation Program made by BSF, fails
e Government's briefing regardless of standing as part of its duty to ensure that the subpoena meets the requirements of Nixon. See United States v. Bergstein, No. I6-CR-746 (PKC), 2017 WL 6887596, at *3 (S.D.N.Y. Dec. 28, 2017). But ex parte Rule 17(c) subpoenas are possible in some circumstances if just
Request 12, which seeks "any" submission to the Epstein Victims' Compensation Program made by BSF, fails
e Government's briefing regardless of standing as part of its duty to ensure that the subpoena meets the requirements of Nixon. See United States v. Bergstein, No. I6-CR-746 (PKC), 2017 WL 6887596, at *3 (S.D.N.Y. Dec. 28, 2017). But ex parte Rule 17(c) subpoenas are possible in some circumstances if just
Request 12, which seeks "any" submission to the Epstein Victims' Compensation Program made by BSF, fails
Page: EFTA00020303 →e Government's briefing regardless of standing as part of its duty to ensure that the subpoena meets the requirements of Nixon. See United States v. Bergstein, No. I6-CR-746 (PKC), 2017 WL 6887596, at *3 (S.D.N.Y. Dec. 28, 2017). But ex parte Rule 17(c) subpoenas are possible in some circumstances if just
Page: EFTA00020305 →Entities connected to both Jeffrey Epstein and Bergstein

Marc Rich
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Lawrence Krauss
PERSONMartin Weinberg
PERSON
Sarah Ferguson
PERSON
David Boies
PERSON
Southern District of New York
ORGANIZATION
Audrey Strauss
PERSON
Chris Tucker
PERSONSecond Circuit
ORGANIZATIONReyes
PERSON
Alison J. Nathan
PERSON
Barneys New York
ORGANIZATION
Cynthia Nixon
PERSON
Brady
PERSON
Aguilar
PERSON
Giglio
PERSON
ALISON J. NATHAN
ORGANIZATION