Epstein Secrets

uly 10.2020.2:06 AN1 • I I mm mod GNsialne Maxwell behind ban as new details emerge Jeffrey Epstein's ex-gw1.0. Wenta. groom and 11 VI • J.66, Epstem's sex aunts by he@ng him Ghislaine Maxwell, a British socialite and longtime companion of disgraced financier Jeffrey Epstein, is facing a reckonin

ficant facts since briefing closed on the first round of review of sealed materials. After many months of relentless negative media coverage of Mr. Epstein and allegations that Ms. Maxwell was involved in his criminal activities, the government secured an indictment against her. On July 2, one day after

his apartments in New York City — near his own townhouse, where he would allegedly rape her the next year. MAIM Feds finally start investigating Jeffrey Epstein's gal pal Ghislaine Maxwell "In 1997, while at Epstein's townhouse on 9 East 71st Street in the City of New York. Epstein asked 17-year-old Doe if sh

TA00075089 ca3FtsVrit5164 Get. PtiftitPtiktivektA8Siig W*40441319 Q. List all the people under the age of 18 that you interacted with at any of Jeffrey's properties? A. I'm not aware of anybody that I interacted with, other than obviously (the plaintiff) who was 17 at this point. (Title 18, Unit

months of relentless negative media coverage of Mr. Epstein and allegations that Ms. Maxwell was involved in

a July 29, 2020 Page 2 courts have recognized, temporary stays of unseal orders are appropriate so that "[t]he genie is [not] out of the bottle," Gambale v. Deutsche Bank AG, 377 F.3d 133, 144 (2d Cir. 2004), before the interested parties have an opportunity to seek review of the orders. See, e.g., United Staten. Martom

likely relevant to its pending Virgin Islands Criminally Influenced and Corrupt Organizations Act ("CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities before the Superior Court of the U.S. Virgin Islands. See Exhibit A hereto (USVI's operative First Amended C

Virgin Islands Criminally Influenced and Corrupt Organizations Act ("CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities before the Superior Court of the U.S. Virgin Islands. See Exhibit A hereto (USVI's operative First Amended Complaint, filed Feb

"CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities

"CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities b

of access to certain judicial documents. Guzik v. Albright, No. 16-CV-2257 (JPO), 2018 U.S. Dist. LEXIS 196006, at *9 (S.D.N.Y. Nov. 16, 2018); see Gambale v. Deutsche Bank AG, 377 F.3d 133, 140 (2d Cir. 2004). The initial issue on a non-party's request for access to a document filed in a court is whether it is a "judicia

likely relevant to its pending Virgin Islands Criminally Influenced and Corrupt Organizations Act ("CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities before the Superior Court of the U.S. Virgin Islands. See Exhibit A hereto (USVI's operative First Amended C

Virgin Islands Criminally Influenced and Corrupt Organizations Act ("CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities before the Superior Court of the U.S. Virgin Islands. See Exhibit A hereto (USVI's operative First Amended Complaint, filed Feb

"CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities

"CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities b

of access to certain judicial documents. Guzik v. Albright, No. 16-CV-2257 (JPO), 2018 U.S. Dist. LEXIS 196006, at *9 (S.D.N.Y. Nov. 16, 2018); see Gambale v. Deutsche Bank AG, 377 F.3d 133, 140 (2d Cir. 2004). The initial issue on a non-party's request for access to a document filed in a court is whether it is a "judicia

.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

e Ins. Co. v. Electrolux Home Prods., Inc., 287 F.R.D. 130 (E.D.N.Y. 2012) 11, 12 In re EPDM Antitrust Litt., 255 F.R.D. 308 (D. Conn. 2009) 12 Gambale v. Deutsche Bank AG, 377 F.3d 133 (2d Cir. 2004) v. Maxwell, No. 15 Civ. 7433, 2017 WL 1787934 (S.D.N.Y. May 3, 2017) 10, 11 10 Intl Equity Investments, Inc. v. Op

numerous allegations, over the span of four years, that Ms. Maxwell participated in a scheme causing her to be "sexually abused and trafficked" by Jeffrey Epstein. 2 EFTA00074911 Case 20-2413, Document 10-1, 07/30/2020, 2896538, Pagel 0 of 38 Plaintiff, a public figure required to prove actual malice, liti

and sexual trafficking of minors. Her lawyers intended to prove the defamation claim solely by, in effect, "prosecuting" Ms. Maxwell as a proxy for Epstein. Plaintiff chose this course of action because even she admitted some of her public statements were false. Discovery in the case was correspondingl

ng her to be "sexually abused and trafficked" by Jeffrey Epstein. 2 EFTA00074911 Case 20-2413, Documen

wn v. Maxwell, 929 F.3d 41 (2d Cir. 2019) passim Dubose v. Pierce, 487 U.S. 1229 (1988) 15 Dubose v. Pierce, 761 F.2d 913 (2d Cir. 1985) 15 Gambale v. Deutsche Bank AG, 377 F.3d 133 (2d Cir. 2004) 16 Hilton v. Braunskill, 481 U.S. 770 (1987) 13 Hunt v. Enzo Biochem, Inc., 904 F. Supp. 2d 337 (S.D.N.Y. 2012)

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

tive order is a decision committed to the sound discretion of the trial court." TheStreet Com, 273 F.3d at 231 (internal quotation omitted); accord Gambale v. Deutsche Bank AG, 377 F.3d 133, 142 n.7 (2d Cir. 2004) ("If reliance would be unreasonable, it is within the discretion of the court to vacate or modify a protectiv

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

tive order is a decision committed to the sound discretion of the trial court." TheStreet.Com, 273 F.3d at 231 (internal quotation omitted); accord Gambale v. Deutsche Bank AG, 377 F.3d 133, 142 n.7 (2d Cir. 2004) ("If reliance would be unreasonable, it is within the discretion of the court to vacate or modify a protectiv