Epstein Secrets

ein's properties in New York, Florida, and New Mexico, between approximately 1994 and 1997. As the Indictment details, Maxwell played a key role in Epstein's abuse of minors by helping Epstein to identify, groom, and ultimately abuse underage girls. ' While the Government understands that letters from

rom a scheme to sexually abuse underage girls at Jeffrey Epstein's properties in New York, Florida, and Ne

2015 WL 8207496, at *24 (E.D.N.Y. Dec. 7, 2015). The complaint in this civil action alleges that Maxwell facilitated the sexual abuse of a minor by Jeffrey Epstein in the 1990s. Those allegations will, by definition, touch on matters relating to the pending Indictment. Indeed, based on a review of the civil com

urts routinely grant applications to stay civil proceedings in order to protect a pending criminal case. See, e.g., Johnson v. New York City Police Dep't, 01 Civ. 6570 (RCC) (JCF), 2003 WL 21664882, at *2 (S.D.N.Y. July 16, 2003); Okoli v. Cty. of Nassau, 15 Civ. 0701 (JS) (SIL), 2015 WL 8207496, at *

dar Online submitted a FOIA requests to the FBI collectively seeking "all documents relating to the FBI's investigation and prosecution of financier Jeffrey Epstein, who plead guilty to one count of felony solicitation of prostitution in August 2006. Dkt. No. 12-2, Ex. B; see Declaration of Michael G. Seidel, da

(b)(7)(A). Many of the records sought by the Radar Online fall at the heart of this exemption, and the FBI has withheld them individually, prior to Esptein's arrest, and categorically, after Esptein's arrest. Other FOIA exemptions also justify the FBI's withholding of records in response to the FOIA re

ecords at the core of the criminal prosecution of Jeffrey Epstein, prior to his passing, and the current p

2(bX7XC). Under Exemption 7(C), a court again "balance[s] the public interest in disclosure against the [privacy] interest." Associated Press v. US. Dep't of Defense,554 F.3d 274, 284 (2d Cir. 2009). In this analysis, "[t]here is only one relevant public interest, that of opening agency action to the li

ow He Hanged Himself in Suicide, N.Y. Times (Aug. 16, 2019) 7 Ali Watkins, Danielle Ivory & Christina Goldbaum, Inmate 76318-054: The Last Days of Jeffrey Epstein (Aug. 17, 2019) 5, 6 Julie K. Brown, Jeffrey Epstein Wasn't Trafficking Women — And He Didn't Kill Himself, Brother Says, Miami Herald (Nov. 14, 2

ords could interfere with the law enforcement proceedings it cites—the prosecution of murder defendant Nicholas Tartaglione, who shared a cell with Epstein for a brief period of time, and the prosecution of the two correctional officers who failed to perform prisoner counts at the time of Epstein's suic

0 OTHER AUTHORITIES Ali Watkins & Michael Gold, Jeffrey Epstein Autopsy Results Show He Hanged Himself in

ption 5, the deliberative process privilege "does not operate indiscriminately to shield all decision-making by public officials." N.Y. Times Co. v. Dep't of Def., 499 F. Supp. 2d 501, 514 (S.D.N.Y. 2007). Moreover, the Government's Exemption 5 withholdings cannot survive because BOP has failed to meet

ow He Hanged Himself in Suicide, N.Y. Times (Aug. 16, 2019) 7 Ali Watkins, Danielle Ivory & Christina Goldbaum, Inmate 76318-054: The Last Days of Jeffrey Epstein (Aug. 17, 2019) 5, 6 Julie K. Brown, Jeffrey Epstein Wasn't Trafficking Women — And He Didn't Kill Himself, Brother Says, Miami Herald (Nov. 14, 2

ords could interfere with the law enforcement proceedings it cites—the prosecution of murder defendant Nicholas Tartaglione, who shared a cell with Epstein for a brief period of time, and the prosecution of the two correctional officers who failed to perform prisoner counts at the time of Epstein's suic

0 OTHER AUTHORITIES Ali Watkins & Michael Gold, Jeffrey Epstein Autopsy Results Show He Hanged Himself in

ption 5, the deliberative process privilege "does not operate indiscriminately to shield all decision-making by public officials." N.Y. Times Co. v. Dep't of Def., 499 F. Supp. 2d 501, 514 (S.D.N.Y. 2007). Moreover, the Government's Exemption 5 withholdings cannot survive because BOP has failed to meet

ow He Hanged Himself in Suicide, N.Y. Times (Aug. 16, 2019) 7 Ali Watkins, Danielle Ivory & Christina Goldbaum, Inmate 76318-054: The Last Days of Jeffrey Epstein (Aug. 17, 2019) 5, 6 Julie K. Brown, Jeffrey Epstein Wasn't Trafficking Women — And He Didn't Kill Himself, Brother Says, Miami Herald (Nov. 14, 2

ords could interfere with the law enforcement proceedings it cites—the prosecution of murder defendant Nicholas Tartaglione, who shared a cell with Epstein for a brief period of time, and the prosecution of the two correctional officers who failed to perform prisoner counts at the time of Epstein's suic

0 OTHER AUTHORITIES Ali Watkins & Michael Gold, Jeffrey Epstein Autopsy Results Show He Hanged Himself in

ption 5, the deliberative process privilege "does not operate indiscriminately to shield all decision-making by public officials." N.Y. Times Co. v. Dep't of Def., 499 F. Supp. 2d 501, 514 (S.D.N.Y. 2007). Moreover, the Government's Exemption 5 withholdings cannot survive because BOP has failed to meet

8. Moreover, on the facts of this case, the Government's construction leads to an absurd result. As the Court is aware, the Government arranged for Epstein to execute his NPA on about September 24, 2007 — in secret. At that time, the victims could not "assert[] the right to be heard before or during th

ommenced within three years after the disability ceases." 28 U.S.C. § 2401(a) (2012) (emphasis added). In this case, Jane Doe No. 3 was hiding from Jeffrey Epstein and his co-conspirators in Australia from the time her claim accrued until October 2013, when she returned to the United States. See Ex. I at 3 ("I

d). In this case, Jane Doe No. 3 was hiding from Jeffrey Epstein and his co-conspirators in Australia from

e Myers I TooJay's Mgmt. Corp., 640 F.3d 1278, 1286 (11th Cir. 2011) (courts "are not licensed to practice statutory remodeling"); Wright. Sec'y for Dep't of Corrs., 278 F.3d 1245, 1255 (1 I th Cir.2002) ("Our function is to apply statutes, to carry out the expression of the legislative will that is emb