Epstein Secrets

Boies it was issued. The materials provided by Boies Schiller inclnin addition tIl inscripts of Maxwell and other individuals, materials proday N/14!IME lles, and court-relatedpleadings in the ase. 7. Magistrate Juda jOrder On or about April 9, 201

on in ordering the unsealing of the deposition materials and that Maxwell's interests outweighed the public's interests in access to the materials. n. Maxwell, No.20-2413 (2d Cir.), (Dkt. No. 140-1 at 2). On October 19, 2020, the Second Circuit found that Judge Preska "correctly held that the deposition ma

eeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020, https://www.nydailynews.corninew-york/ny-jeffrey-epstein-maxwell-case-20201013- jmzh17zdr

osecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily New

al. On February 8, 2021, Judge Preska "decline[d] Ms. Maxwell's invitation to reconsider its order" and noted

er assertion that was instrumental in fomenting the Maxwell prosecution" (Def. Mot 3 at 2) (emphasis in orig

ates v. Calandra,414 U.S. 338, 343(1974)). "Wide latitude in gatheringevidence is vital to the grand jury's investigative function." Id. at 422; see Branzburg v. Hayes, 408 U.S. 665, 688 (1972) ("Although the powers of the grand jury are not unlimited and are subject to the 78 EFTA00100045 supervision

provided to Boies Schiller shortly after it was issued. The materials provided by Boies Schiller included, in addition to deposition transcripts of Maxwell and other individuals, materials produced by Maxwell, and non-parties, and court-related pleadings in the civil case. 7. Magistrate Judge Netburn

eeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020, hftps://www.nydailynews.cominew-yorlc/ny-j effrey-epstein-maxwel I-case-20201013- jrnzhl7

al. On February 8, 2021, Judge Preska "decline[d] Ms. Maxwell's invitation to reconsider its order" and noted

osecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily New

hat "Boies Schiller was instrumental in fomenting the Maxwell prosecution" (Def. Mot. 3 at 2) (emphasis in ori

s v. Calandra, 414 U.S. 338, 343 (1974)). "Wide latitude in gathering evidence is vital to the grand jury's investigative function." Id. at 422; see Branzburg v. Hayes, 408 U.S. 665, 688 (1972) ("Although the powers of the grand jury are not unlimited and are subject to the 78 EFTA00103103 supervision

provided to Boies Schiller shortly after it was issued. The materials provided by Boies Schiller included, in addition to deposition transcripts of Maxwell and other individuals, materials produced by Giuffre, Maxwell, and non-parties, and court-related pleadings in the civil case. 7. Magistrate Judge

eeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020, https://wwvv.nydailynews.corninew-yorlc/ny-jeffity-epstein-maxwell-case-20201013- jrnzhl7

al. On February 8, 2021, Judge Preska "decline[d] Ms. Maxwell's invitation to reconsider its order" and noted

osecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily New

hat "Boies Schiller was instrumental in fomenting the Maxwell prosecution" (Def. Mot. 3 at 2) (emphasis in ori

s v. Calandra, 414 U.S. 338, 343 (1974)). "Wide latitude in gathering evidence is vital to the grand jury's investigative function." Id. at 422; see Branzburg v. Hayes, 408 U.S. 665, 688 (1972) ("Although the powers of the grand jury are not unlimited and are subject to the 78 EFTA00077710 supervision

provided to Boies Schiller shortly after it was issued. The materials provided by Boies Schiller included, in addition to deposition transcripts of Maxwell and other individuals, materials produced by Giuffre, Maxwell, and non-parties, and court-related pleadings in the civil case. 7. Magistrate Judge

eeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020, https://wwvv.nydailynews.corninew-yorlc/ny-jeffity-epstein-maxwell-case-20201013- jrnzhl7

al. On February 8, 2021, Judge Preska "decline[d] Ms. Maxwell's invitation to reconsider its order" and noted

osecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily New

hat "Boies Schiller was instrumental in fomenting the Maxwell prosecution" (Def. Mot. 3 at 2) (emphasis in ori

s v. Calandra, 414 U.S. 338, 343 (1974)). "Wide latitude in gathering evidence is vital to the grand jury's investigative function." Id. at 422; see Branzburg v. Hayes, 408 U.S. 665, 688 (1972) ("Although the powers of the grand jury are not unlimited and are subject to the 78 EFTA00039525 supervision

materials. Giuf•e v. Maxwell, No. 20-2413 (2d Cir.) (Dkt. No. 140-1 at 2). On October 19, 2020, the Second Circuit found that Judge Preska "correctly held that the deposition ma

as "insist[ing] [a second meeting] never happened." 36 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020, https://wwvv.nydailynews.corninew-yorlc/ny-jeffrey-epstein-maxwell-case-20201013- jrnzhl7

al. On February 8, 2021, Judge Preska "decline[d] Ms. Maxwell's invitation to reconsider its order" and noted

osecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily New

her assertion that was instrumental in fomenting the Maxwell prosecution" (Def. Mot. 3 at 2) (emphasis in ori

s v. Calandra, 414 U.S. 338, 343 (1974)). "Wide latitude in gathering evidence is vital to the grand jury's investigative function." Id. at 422; see Branzburg v. Hayes, 408 U.S. 665, 688 (1972) ("Although the powers of the grand jury are not unlimited and are subject to the supervision of a judge, the lon

Maxwell from Prosecution 15 1. The NPA Is Limited to Particular Crimes Between 2001 and 2007 15 2. The NPA Does Not Confer Enforceable Rights On Maxwell 17 C. The Defendant Has Offered No Basis for Additional Discovery or a Hearing 21 II. The Indictment Is Timely 23 A. Statutory Background 24

criminal case could resolve disputed issues in the Doe case. Such concerns are not present in Giuffre v. Maxwell. 57 EFTA00095149 claims against Ghislaine Maxwell have been asserted." (20 Civ. 484 (DCF) (JGK), Dkt. No. 80 at 2). The defendant's baseless conjecture about the Government's nefarious reasons for d

x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS

(Def. Mot. 1 at 32 ("For the foregoing reasons, Ms. Maxwell respectfully requests that the Court dismiss the

ons, Inc., No. 97 Civ. 7587 (JGK), 1998 WL 88745 (S.D.N.Y. Feb. 27, 1998) 102 Boyd v. United States, 116 U.S. 616 (1886) 101 iv EFTA00095071 Branzburg v. Hayes, 408 U.S. 665 (1972) 78 Bridges v. United States, 346 U.S. 209 (1953) 38 Bronston v. United States, 409 U.S. 352 (1973) 121 Bryson

651, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP (the "A in connection with the matter v. Ghislaine Maxwell, et al. ("M"), 15 Civ. 7433 (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A. Background As described in the Application, the G

nformation simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). CONFIDENTIAL SDNY_GM_00000849 EFTA00066435 Page

simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). CONFIDENTIAL SDNY_GM_00000849 EFTA00066435 Page 4 Martin

such investigations it may compel the production of documentary evidence or the testimony of witnesses, as it deems necessary." Id. at 421-22; see Branzburg v. Hayes, 408 U.S. 665, 688 (1972) ("Although the powers of the grand jury are not unlimited and are subject to the supervision of a judge, the longstanding

1651, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP the "A in connection with the matter v. Ghislaine Maxwell, et al. (a), (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A. Background As described in the Application, the Government has s

nformation simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). EFTA00084803 Page 4 Martindell, the district cour

simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). EFTA00084803 Page 4 Martindell, the district court opined

such investigations it may compel the production of documentary evidence or the testimony of witnesses, as it deems necessary." Id. at 421-22; see Branzburg v. Hayes, 408 U.S. 665, 688 (1972) ("Although the powers of the grand jury are not unlimited and are subject to the supervision of a judge, the longstanding

51, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP (the "A in connection with the matter v. Ghislaine Maxwell, et at (a"), 15 Civ. 7433 (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A. Background As described in the Application, the Gov

nformation simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). CONFIDENTIAL SDNY_GM_00000849 EFTA_00114933 EFTA0

simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). CONFIDENTIAL SDNY_GM_00000849 EFTA_00114933 EFTA01263242

such investigations it may compel the production of documentary evidence or the testimony of witnesses, as it deems necessary." Id. at 421-22; see Branzburg v. Hayes, 408 U.S. 665, 688 (1972) ("Although the powers of the grand jury are not unlimited and are subject to the supervision of a judge, the longstanding

n Sex Suits. M. POST, Oct. 12, 2009 ("Florida lawyer Brad Edwards. who represents three of the 'Jane Does' who are suing Epstein, told Page Six that Phislaine] Maxwell would be questioned over her knowledge of how Epstein procured many of the girls.") (bold in original); Susan Spencer-Wendel, Judge Agrees

are suing Epstein, told Page Six that Phislaine] Maxwell would be questioned over her knowledge of how Ep

F.3d 62 (2d Cir. 1994) 13 Baxter v. Palmigiano, 425 U.S. 308 (1976) 21 Buttner v. Berg & Dorf, 138 ad 439, 525 MI.2d 858 (2d Dep't 1988) 19 Branzburg v. Hayes, 408 U.S. 665 (1972) 23 Brown & Williamson Tobacco CS E. v. Wigand, 1996 WL 350827 (Sup. Ct. OS Co. Feb. 28, 1996), affd, 228 ..2r1187,

Merriam-Webster Online (2010), /off-the-record ("`off-the-record': given or made in confidence and not for publication <off-the-record comments>"); Branzburg v. Hayes, 408 U.S. 665, 728 (1972) (Stewart J., dissenting) (defining "confidentiality" as "the promise or understanding that names or certain aspects of co