Epstein Secrets

to disclosure of confidential material in ME v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) and a related app

Use of Discovery Materials GM_00000847-962 Dear Ms. Maxwell is actively litigating issues related to disclosu

VIA EMAIL Assistant United States Attorney New York, New York 10007 Re: Conferral Concerning Use of Discovery Materials GM_00000847-962 Dear Ms. Maxwell is actively litigating issues related to disclosure of confidential material in ME v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) and a related appeal

Use of Discovery Materials GM_00000847-962 Dear Ms. Maxwell is actively litigating issues related to disclosure of confidential material in ME v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) and a related appeal in the United States Court of Appeals for the Second Circuit, 20-2413. We intend to ask Judge Nathan f

s regarding those pleadings, and ex parte rulings on the pleadings. As least one set of individuals outside this prosecution, the Boies, Schiller & Flexner lawyers cooperating with the Government, are aware of the Unsealing Materials. Moreover, these are the types of pleadings that the Second Circuit h

.com [email protected] Re: Response to Government Letters dated May 4, and May 6, 2021 Regarding F.R. Crim. P. 17(c) Subpoena, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, On March 15, 2021, Ms. Maxwell asked the Court to issue a F.R.Crim.P. 17(c)(3) subpoena for production of evid

May 6, 2021 Regarding F.R. Crim. P. 17(c) Subpoena, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, On March 15, 2021, Ms. Maxwell asked the Court to issue a F.R.Crim.P. 17(c)(3) subpoena for production of evidence controlled by Boies, Schiller, and Flexner ("BSF") lawyers work

g F.R. Crim. P. 17(c) Subpoena, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, On

330 (MN) Dear Judge Nathan, On March 15, 2021, Ms. Maxwell asked the Court to issue a F.R.Crim.P. 17(c)(3)

n March 15, 2021, Ms. Maxwell asked the Court to issue a F.R.Crim.P. 17(c)(3) subpoena for production of evidence controlled by Boies, Schiller, and Flexner ("BSF") lawyers working with the government on behalf of alleged (now-adult) witnesses. In her ex-parte application, Ms. Maxwell provided reasons f

own internal work product. my own 24 that you maintain with Jeffrey Epstein. Chislaine 24 internal dynamic. my own thinking process. I didnt 25 Maxwell or anyone else a part of that agreement. 25 think it was necessary for me to call you and ask 718 720 1 MR. SIMPSON: Object to the form as 1

leman's (2) 709:8 714:21 genuinely (1) 753:16 Gertner (6) 765:10 766:3,5 766:11,18,24 getting (6) 680:10 681:5 693:25 721:13 754:14 761:13 Ghislaine (1) 717:24 give (26) 653:8 668:5,8 669:5,7 680:19 682:19 697:19 701:8 707:10 707:12 716:1 721:23 724:17 725:22 731:5 731:11,21 734:15 741:

't be any 4 be clear. Mr. Epstein's counsel has not 4 testimony with respect to Boies Schiller 5 appeared in this case. I argued this issue 5 Flexner or those allegations that have 6 before the judge. and I have a confidentiality 6 repetitively come up in the deposition outside 7 order from J