Epstein Secrets

12 WL 5395249 (S.D.N.Y. Nov. 5, 2012) 2 iii EFTA00100289 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

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

now disclosed several documents "with respect to any criminal investigations" 3 Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jed Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020), https://www.nydailynews.corninew-yorktny-jeffrey-epstein-maxwell-case-2020

LES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

vernment disclosed the 90,000 pages of material it obtained from Boies Schiller.2 The government's due process violation warrants suppression. E.g., Raheem v. Kelly, 257 F.3d 122, 135 (2d Cir. 2001) (suppression for due process violation). Second, because the government violated Martindell not only by denying M

12 WL 5395249 (S.D.N.Y. Nov. 5, 2012) 2 iii EFTA00097333 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

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 which then compelled Maxwell, over objection, to answer irrelevant and highly prejudicial person

LES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

vernment disclosed the 90,000 pages of material it obtained from Boies Schiller.2 The government's due process violation warrants suppression. E.g., Raheem v. Kelly, 257 F.3d 122, 135 (2d Cir. 2001) (suppression for due process violation). Second, because the government violated Martindell not only by denying M

12 WL 5395249 (S.D.N.Y. Nov. 5, 2012) 2 iii EFTA00097651 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

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 which then compelled Maxwell, over objection, to answer irrelevant and highly prejudicial person

LES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Mennin • er Christian R. E

vernment disclosed the 90,000 pages of material it obtained from Boies Schiller.2 The government's due process violation warrants suppression. E.g., Raheem v. Kelly, 257 F.3d 122, 135 (2d Cir. 2001) (suppression for due process violation). Second, because the government violated Martindell not only by denying M