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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
in a court is whether it is a "judicial document." Trump v. Deutsche Bank AG, 940 F.3d 146, 150-51 (2d Cir. 2019) (citing Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119 (2d Cir. 2006)). Merely filing a document with a court "'is insufficient to render that paper a judicial document subject to the
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
in a court is whether it is a "judicial document." Trump v. Deutsche Bank AG, 940 F.3d 146, 150-51 (2d Cir. 2019) (citing Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119 (2d Cir. 2006)). Merely filing a document with a court "'is insufficient to render that paper a judicial document subject to the
to Settle Epstein-Related Claims The New York Times (07/21, Goldstein) reported that billionaire investor Leon Black agreed to pay $62.5 million to the U.S. Virgin Islands in January to be released from any potential claims arising out of the territory's three-year investigation into the sex trafficking operation of th
may have known some Oneida Nation members, was gang-raped and killed. The article stated that FBI agents reportedly made visits to residents of the Onondaga reservation, a bigger Native American territory 40 miles from the Oneida Nation Territory, as recently as last week in their latest efforts to pers
Entities connected to both U.S. Virgin Islands and Onondaga

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSON
New York
LOCATION
Alan Dershowitz
PERSON
George W. Bush
PERSONthe Southern District
LOCATION
Donald Trump
PERSON
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSONLeon Black
PERSONJane Doe
PERSON
Julie K. Brown
PERSON
Kenneth Marra
PERSON
Martha Stewart
PERSON
Samantha Power
PERSON
Joe Biden
PERSON
Paul Cassell
PERSON