Epstein Secrets

the need for a trial and are pleased with the result' , 33, had persuaded a judge to throw out a motion preventing her from suing British socialite Ghislaine Maxwell, 55, for defamation The defamation suit alleged Maxwell instructed her spokesman to attack honesty and truthfulness and to accuse her of lying For

rsuaded a judge to throw out a motion preventing her from suing British socialite Ghislaine Maxwell, 55, for defamation The defamation suit alleged Maxwell instructed her spokesman to attack honesty and truthfulness and to accuse her of lying For internal use only SDNY_GM_00059503 CONFIDENTIAL - PURS

87111-8318 1602 PENNSYLVANIA ST NE APT E ALBUQUERQUE, NM 87110-5552 1501 TRAMWAY BLVD NE APT C206 ALBUQUERQUE, NM 87112-6108 14 MAX'WELL, GHISLAINE 116E 65TH ST 133-78-XXXX 12/1961 NOELLE NEW YORK, NY 10065- 12/1961 MAXWELL GHISLANE N 7007 For internal use only SDNY_GM_00059558 CONFIDE

UERQUE, NM 87111-8318 1602 PENNSYLVANIA ST NE APT E ALBUQUERQUE, NM 87110-5552 1501 TRAMWAY BLVD NE APT C206 ALBUQUERQUE, NM 87112-6108 14 MAX'WELL, GHISLAINE 116E 65TH ST 133-78-XXXX 12/1961 NOELLE NEW YORK, NY 10065- 12/1961 MAXWELL GHISLANE N 7007 For internal use only SDNY_GM_000595

F.3d at 1347. "The district court has 'substantial discretion' in determining whether grand jury materials should be released." Id. at 1349 (quoting Douglas Oil Co. v. Petrol Stops N.W., 441 U.S. 211, 223, 99 S. Ct. 1667, 60 L. Ed. 2d 156 (1979)). For internal use only SDNY_GM_00059572 CONFIDENTIAL - PURSUANT

ellaneous Case is EFTA00080937 Page 2 active and ongoing, and indeed resulted in new charges being brought just this month. See United States v. Maxwell, 20 Cr. 330 (AJN). The existence of the Government's application related to its efforts to permit compliance with a grand jury subpoena, and the spe

criminal grand jury investigation, which, despite significant coverage in the media in connection with charges brought against Jeffrey Epstein and Ghislaine Maxwell, nevertheless continues to include matters not publicly known or confirmed through public filings or Government statements. The Government notes th

with charges brought against Jeffrey Epstein and Ghislaine Maxwell, nevertheless continues to include matte

the destruction of or tampering with evidence, or otherwise seriously jeopardize an investigation, the materials should not be unsealed. See, e.g., Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 218 n.9 (1979) ("Since the 17th century, grand jury proceedings have been closed to the public; and record

ited States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in response to the Court's order dated January 26, 2021 provi

, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Govern

New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: Th

er the Fourth and Fifth Amendments (Motion II) are narrowly tailored to protect the integrity of the Government's ongoing investigation. See, e.g., Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 218 n.9 (1979) ("Since the 17th century, grand jury proceedings have been closed to the public; and record

ING ATTORNEY: Kerrie L. Campbell [name of attorney, whh firm, address. glione number and e-mail] KCampbell-Law, PLLC BOIES SCHILLER FLEXNER UP v. Maxwell OPPOSING ATTORNEY:Sigrid moe-awieY 1629 K St., NW, Suite 300, Washington, DC 20006 401 E. Las Olas Blvd. Suite 1200 Fort Lauderdale, FL, 33301 2

co-counsel with: (name/firm) Defendant-Appellee Ghislaine Maxwell IZIAmicus (in support of: (party/designation)

co-counsel with: (name/firm) Defendant-Appellee Ghislaine Maxwell IZIAmicus (in support of: (party/design

sarily jeopardize the privacy and reputational interests of the named individuals. United States v. Smith, 776 F.2d 1104, 1114 (3d Cir. 1985); cf. Douglas Oil Co. of Ca. v. Petrol Stops NW, 441 U.S. 211, 219 (1979) (observing that grand jury secrecy is designed in part to "assure that persons who are accused