Epstein Secrets

1(a)(2). In connection with her motion, Plaintiff filed a proposed order of dismissal imposing certain conditions (the "Proposed Order"). Defendant Ghislaine Maxwell opposed the motion. For the following reasons, subject to Plaintiff's consent, dismissal is granted pursuant to the terms of the Proposed Order modi

suant to the terms of the Proposed Order modified as described below. I. BACKGROUND On November 12, 2019, Plaintiff filed a Complaint against Ms. Maxwell and Defendants Darren K. Indyke and Richard D. Kahn in their official capacities as appointed executors of the Estate of Jeffrey E. Epstein (the "E

ain conditions (the "Proposed Order"). Defendant Ghislaine Maxwell opposed the motion. For the following rea

ber 12, 2019, Plaintiff filed a Complaint against Ms. Maxwell and Defendants Darren K. Indyke and Richard D. K

Filed 02/10/21 Page 2 of 6 Epstein's and Ms. Maxwell's alleged sexual abuse of Plaintiff. Defendants did not file counterclaims. On June 2, 2020, the Superior Court of the United States Virgin Islands granted the Co- Executors' motion to establish the Epstein Victims' Compensation Program, a voluntary independen

EFTA00073262 Case 1:15-cv-07433-LAP Document 1111 Filed 09/01/20 Page 4 of 14 • (a) All currently sealed documents filed in support of Defendant Ghislaine Maxwell's motion for summary judgment (ECF No. 540 to 543, inclusive); • (b) All currently sealed documents filed in support of Plaintiff Virginia L. Giuffr

ruary 11, 2020). Access to other judicial documents in this action has already been granted to intervening private parties in interest, see Brown v. Maxwell, 929 F.3d 41 (2d Cir. 2019), and also is the subject of ongoing litigation before this Court. See, e.g., ECF No. 1096-1108. The 1 EFTA00073260 C

F NEW YORK Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-LAP

ed 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 February 11, 2020). Access to other judicial docu

EFTA00077313 Case 1:15-cv-07433-LAP Document 1111 Filed 09/01/20 Page 4 of 14 • (a) All currently sealed documents filed in support of Defendant Ghislaine Maxwell's motion for summary judgment (ECF No. 540 to 543, inclusive); • (b) All currently sealed documents filed in support of Plaintiff opposition to Def

ruary 11, 2020). Access to other judicial documents in this action has already been granted to intervening private parties in interest, see Brown v. Maxwell, 929 F.3d 41 (2d Cir. 2019), and also is the subject of ongoing litigation before this Court. See, e.g., ECF No. 1096-1108. The EFTA00077311 Case

T SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-LAP

ed 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 February 11, 2020). Access to other judicial docu

ly on Epstein, he would only cause them more and more harm. 44. As demonstrated by the above, Epstein treated the girls he abused in the same way Ghislaine Maxwell, his co-conspirator, viewed them: like "they[] [were] nothing, these girls," like "[t]hey [we]re trash." Epstein's Abuse of Doe Was Directly and In

ed the girls he abused in the same way Ghislaine Maxwell, his co-conspirator, viewed them: like "they[] [w

tein treated the girls he abused in the same way Ghislaine Maxwell, his co-conspirator, viewed them: like "t

er situated...to the then acting Trustees of The 1953 Trust." 67. On August 26, 2019, Defendant Darren K. Indyke filed a Certificate of Trust with the Superior Court for the Virgin Islands, confirming that he and Defendant Richard D. Kahn are the two Trustees of The 1953 Trust. See Certificate of Trust, In the Ma

F NEW YORK JANE DOE, Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, an individual, Defendants. Case No. COMPLAINT FOR DAMAGES DEMAND FOR JURY TRIAL Plaintiff Jane Doe ("Doe" or "Plaintiff") alleges as follows:

le and convicted sex offender Jeffrey Epstein ("Epstein"). It all started in when 13-year-old Jane Doe met Epstein and Defendant Ghislaine Maxwell ("Maxwell") at a summer camp in Michigan. Jane Doe was their first known victim and was subsequently abused by Epstein and Maxwell for years as a girl, suff

executors of the ESTATE OF JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, an individual, Defendants. Case No. C

3 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 31. On August 26, 2019, Defendant Darren K. Indyke filed a Certificate of Trust with the Superior Court for the Virgin Islands, confirming that he and Defendant Richard D. Kahn arc the two Trustees of The 1953 Trust. 32. On September 6, 2019, Magistr

US lifts upper limit on government-backed home mortgages to almost $1m ABC News • 3 students killed, 6 others injured at Michigan school shooting; Ghislaine Maxwell accuser testifies on Day 2 of trial; CNN suspends Chris Cuomo for how he allegedly assisted his brother CBS News • At least 3 dead in Michigan sch

rs injured at Michigan school shooting; Ghislaine Maxwell accuser testifies on Day 2 of trial; CNN suspend

ed, 6 others injured at Michigan school shooting; Ghislaine Maxwell accuser testifies on Day 2 of trial; CNN

er Office of Federal Financial Management Office of Management and Budget, Ebony M. Scott, of the District of Columbia, to be an Associate Judge of the Superior Court of the EFTA00160896 District of Columbia and Donald Walker Tunnage of the District of Columbia to be an Associate Judge of the Superior Court of

rable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Maxwell. No. 20 Cr. 330 Dear Judge Nathan: We represent the independent, neutral administrator of the Epstein Victims' Compensation Program (the "EVCP").

is "otherwise procurable" or, indeed, already in Ms. Maxwell's possession. See United States v. Pena, No. 15

arial, [and] confidential" basis.2' For example, the EVCP operates "entirely free from any interference or control by the Epstein " Ex. G (order of the Superior Court of t1 lit• in Islands Division of St. ( Virgin dated June 2, 2020); see Ex. A ¶¶ 8, 13 Decl.). " Ex. C (6/25/20 Press Release). 16 Maxwell's Mo

r Horizon oil spill, Deputy Administrator of the GM Ignition Switch Compensation Program and Deputy

iminal Activity Lien Notice pursuant to Chapter 30, Title 14 § 610, in the matter ESTATE OF JEFFREY E. EPSTEIN, PROBATE NO. ST-19-PB-80, pending in the Superior Court of the Virgin Islands, Division of St. Thomas and St. John. A civil proceeding. Case No. ST-2020-CV-14. having been instituted by the Government of