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RT SOUTHERN DISTRICT OF NEW YORK Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-LAP THE GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' MEMORANDUM OF LAW IN SUPPORT OF EX PARTE MOTION TO INTERVENE AND FOR CONFIDENTIAL ACCESS TO JUDICIAL RECORDS AND DISCOVERY DOCUMENTS The Governme
V.I.C. §§ 605, 607. The USVI alleges in its CICO action that decedent Jeffrey E. Epstein engaged in a criminal sexual trafficking enterprise in the Virgin Islands, wherein he used his vast wealth and property holdings and a deliberately opaque web of corporations and companies to transport young women and girl
be designated a judicial document, "the item filed must be relevant to the performance of the judicial function and useful in the judicial process." Amodeo, 44 F.3d at 145. Judicial documents are considered on a "continuum," ranging from "matters that directly affect an adjudication to matters that com
ED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-LAP THE GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' MEMORANDUM OF LAW IN SUPPORT OF EX PARTE MOTION TO INTERVENE AND FOR CONFIDENTIAL ACCESS TO JUDICIAL RECORDS AND DISCOVERY DOCUMENTS The Governme
V.I.C. §§ 605, 607. The USVI alleges in its CICO action that decedent Jeffrey E. Epstein engaged in a criminal sexual trafficking enterprise in the Virgin Islands, wherein he used his vast wealth and property holdings and a deliberately opaque web of corporations and companies to transport young women and girl
be designated a judicial document, "the item filed must be relevant to the performance of the judicial function and useful in the judicial process." Amodeo, 44 F.3d at 145. Judicial documents are considered on a "continuum," ranging from "matters that directly affect an adjudication to matters that com
h dispositive motions such as motions for dismissal or summary judgment." Brown v. Maxwell, 929 F.3d 41, 50 (2d Cir. 2019) (citing United States v. Amodeo, 71 F.3d 1044, 1049-50 (2d Cir. 1995) ("Amodeo II")); (b) any minimum presumption of public access is subject to many countervailing interests suppo
Page: EFTA00022965 →ported statements by Plaintiff, Plaintiff's counsel, the United States Attorney for the Southern District of New York, and the Attorney General for the U.S. Virgin Islands, that investigations surrounding the alleged conduct of Mr. Epstein survive his death. It is unclear who are witnesses or targets of any investigati
Page: EFTA00022968 →Entities connected to both U.S. Virgin Islands and Amodeo

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSONthe Southern District
LOCATION
Donald Trump
PERSON
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSON
Bradley Edwards
PERSONJane Doe
PERSONFBI
ORGANIZATION
Julie K. Brown
PERSON
Paul Cassell
PERSON
Deutsche Bank
ORGANIZATION
New York Daily News
ORGANIZATION
Michael Cohen
PERSON
the United States District Court
ORGANIZATION