Epstein Secrets

.S.C. § 1595 3, 4 Other Authorities Fed. R. Civ. P. 24 2, 9, 10 CONFIDENTIAL - FILED UNDER SEAL EFTA00805391 Third-Party Proposed Intervenors Jeffrey Epstein and Lesley Groff (the "Intervenors") respectfully submit this Memorandum of Law in support of their motion to intervene in v. Maxwell, No. 15 Civ.

tective Order") for the reasons set forth below. PRELIMINARY STATEMENT Intervenors are two of the defendants in an action captioned Jane Doe 43 v. Epstein, et al, No. 17 Civ. 616 (JGK), currently pending before Judge John G. Koeltl (the "Jane Doe Matter"). Jane Doe 43 ("Plaintiff" or "Jane Doe") filed

EFTA00805391 Third-Party Proposed Intervenors Jeffrey Epstein and Lesley Groff (the "Intervenors") res

are based primarily on the alleged misconduct of Mr. Epstein. Indeed, shortly after Jane Doe filed her suit ag

er. First, the Protective Order is broadly drafted and the Court has great latitude to amend a protective order with such a broad scope. In re EPDM Antitrust Litig., 255 F.R.D. 308, 319 (D. Conn. 2009) (a blanket protective order is "more likely to be subject to modification than a more specific, targeted order

ion against Ms. Maxwell 8 EFTA00074897 casQaf:q.§fe2et43P-UWnenbegrAeAFAPiiNflieVOM026'acce491th 13 alleged that Ms. Maxwell was a ringleader in Jeffrey Epstein's sex-trafficking scheme, a trusted lieutenant of Epstein's who facilitated his purported trafficking of underage girls to prominent individuals. d

begrAeAFAPiiNflieVOM026'acce491th 13 alleged that Ms. Maxwell was a ringleader in Jeffrey Epstein's sex-trafficking scheme, a trusted lieutenant of Epstein's who facilitated his purported trafficking of underage girls to prominent individuals. defamation action against Mr. Dershowitz alleges that Mr.

13 alleged that Ms. Maxwell was a ringleader in Jeffrey Epstein's sex-trafficking scheme, a trusted lieu

f inquiry the court undertook before granting the order; and (4) the nature of reliance on the order. In re Ethylene Propylene Diene Monomer (EPDM) Antitrust Litig., 255 F.R.D. 308, 318 (D. Conn. 2009). At a broad level, Mr. Dershowitz has simply not demonstrated the existence of an "extraordinary circumstanc

he allegations against Epstein and suggesting that the plea deal constituted Government misconduct. Liam Stack, U.S. Opens Inquiry Into Handling of Jeffrey Epstein's Sex Abuse Case, N.Y. Times (Feb. 6, 2019), https://www.nytimes.com/2019/02/06/usgbi-jeffrey-epstein.html. The exposi garnered attention from the med

hat Maxwell had defamed Giuffre by stating that Giuffre was not the victim of sex crimes perpetrated by, among others, Maxwell and Jeffrey Epstein ("Epstein"). (15-cv- 7433, Dkt. No. 1.) Boies Schiller represented the plaintiff in the litigation, and continues to represent her on a pending post-settlemen

crimes perpetrated by, among others, Maxwell and Jeffrey Epstein ("Epstein"). (15-cv- 7433, Dkt. No. 1.) B

hat reliance was reasonable, where a protective order is, as here, a blanket order entered by stipulation of the parties." In re NASDAQ Mkt.-Makers Antitrust Litig., 164 F.R.D. 346, 356 (S.D.N.Y. 1996). As for the last factor, the nature of the parties' reliance on the order does seem to weigh against modifica

t Ghislaine Maxwell, alleging that Maxwell had defamed by stating that was not the victim of sex crimes perpetrated by, among others, Maxwell and Jeffrey Epstein ("Epstein"). (15-cv- 7433, Dkt. No. I.) Boies Schiller represented the plaintiff in the litigation, and continues to represent her on a pending post

ll, alleging that Maxwell had defamed by stating that was not the victim of sex crimes perpetrated by, among others, Maxwell and Jeffrey Epstein ("Epstein"). (15-cv- 7433, Dkt. No. I.) Boies Schiller represented the plaintiff in the litigation, and continues to represent her on a pending post-settlemen

the allegations against Epstein and suggesting that the plea deal constituted Government misconduct. Liam Stack, US. Opens Inquiry Into Handling of Jeffrey? Epstein's Sex Abuse Case, N.Y. Times (Feb. 6, 2019), https://www.nytimes.com/2019/02/06/usfibi-jeffrey-epstein.html. The expose garnered attention

hat reliance was reasonable, where a protective order is, as here, a blanket order entered by stipulation of the parties." In re NASDAQ Mkt.-Makers Antitrust Litig., 164 F.R.D. 346, 356 (S.D.N.Y. 1996). As for the last factor, the nature of the parties' reliance on the order does seem to weigh against modifica