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ing factual information: I. Grand jury subpoenas were issued to an entity ("Recipient") after the Government opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. The Recipient concluded that it could not turn over materials responsive to the grand jury subpoena absent a
t opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. The Recipi
overnment opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. Th
Federal Rule of Criminal Procedure 16(d)(1), a Court may enter a protective order only after it finds that good cause exists. Within this framework, the Federal Rules of Criminal Procedure leave it to the discretion of the Court to determine whether modification of an existing protective order is warranted.2 To make that dec
ing factual information: I. Grand jury subpoenas were issued to an entity ("Recipient") after the Government opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. The Recipient concluded that it could not turn over materials responsive to the grand jury subpoena absent a
t opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. The Recipi
overnment opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. Th
Federal Rule of Criminal Procedure 16(d)(1), a Court may enter a protective order only after it finds that good cause exists. Within this framework, the Federal Rules of Criminal Procedure leave it to the discretion of the Court to determine whether modification of an existing protective order is warranted.2 To make that dec
hout success, including allowing the Petitioners, that is Jane Does #1 and #2, and their counsel, the opportunity to meet with the U.S. Attorney, as Jeffrey Epstein's attorneys did. Fi Despite the Petitioners' earlier statement to the Court that no additional facts were needed, many hours were spent trying to rev
NERS' "FACTS" WOULD HAVE VIOLATED FED. R. CRIM. P. 6(e) AND/OR CONSTITUTIONAL MANDATES. Several of the "facts" that Petitioners include allege that Epstein and others have committed crimes for which they were never charged or convicted. Others refer to matters that were occurring before the grand jury.
e opportunity to meet with the U.S. Attorney, as Jeffrey Epstein's attorneys did. Fi Despite the Petition
gs. See, e.g., In re Amy Unknown , F.3d , 2011 WL 988882 at *2 (5th Cir. Mar. 22, 2011). ("Crime victims have not been recognized as parties, and the Federal Rules of Criminal Procedure do not allow them to intervene as parties to a prosecution.); United States 1 Aguirre-Gonzalez , 597 F.3d 46, 53 (1st Cir. 2010) ("Notwit
l Brillo Way, Palm Beach, Florida 33480, owned by Jeffrey Epstein (hereinafter, "Epstein's residence"). Th
vestigation 6. In the Spring of 2006, Detective Joseph Recarey with the Town of Palm Beach Police Department contacted me about the investigation of Jeffrey Epstein's solicitation of minors to engage in prostitution and his lewd and lascivious conduct with minors. The FBI opened a case file in July 2006, and your
a State of Florida search warrant at the premises located at 358 El Brillo Way, Palm Beach, Florida 33480, owned by Jeffrey Epstein (hereinafter, "Epstein's residence"). Those CompactFlash memory cards are more fully described as follows: (a) one Ritz Big Print Digital Film 128 Megabyte CompactFlash me
may be used as storage devices that contain contraband, evidence, instrumentalities, or fruits of a crime in the form of electronic data. Rule 41 of the Federal Rules of Criminal Procedure permit the government to search for and seize computer hardware, software, and electronic files that are evidence of crime, contraband, i
Entities connected to both Jeffrey Epstein and the Federal Rules of Criminal

Ghislaine Maxwell
PERSON
United States
LOCATIONSecond Circuit
ORGANIZATION
ALISON J. NATHAN
ORGANIZATIONDefense Counsel
ORGANIZATIONMorales
PERSONUSDC SONY
ORGANIZATION
Lugosch
PERSONOnondaga
LOCATIONBernard Kerik
PERSONAmodeo
PERSONCalderon
PERSONPyramid Co.
ORGANIZATIONWecht
PERSONTeligent
PERSONthe Civil Cases
ORGANIZATIONI. Grand
ORGANIZATION