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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
circumstances militating for or against a finding of timeliness.' D'Amato v. Deutsche Bank, 236 F.3d 78, 84 (2d Cir. 2001) (quoting United States v. Pitney Bowes, Inc., 25 F.3d 66, 70 (2d Cir. 1994)). The interest asserted must be "'direct, substantial, and legally protectable"' and not "'speculative or remo
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
circumstances militating for or against a finding of timeliness.' D'Amato v. Deutsche Bank, 236 F.3d 78, 84 (2d Cir. 2001) (quoting United States v. Pitney Bowes, Inc., 25 F.3d 66, 70 (2d Cir. 1994)). The interest asserted must be "'direct, substantial, and legally protectable"' and not "'speculative or remo
ign. We frequently discuss world trends as each of us sees them." SPOILS OF SUCCESS From top: Epstein's 70- acre island. Little St. James. in the U.S. Virgin Islands—he now calls it Little St. Jeff: Epstein with President Clinton in Brunei. 2002: Leslie Wexner with his future wife, Abigail, at the 1990 C.F.D
Goldman, Sachs & Co.; former President, Federal Reserve Bank of New York Alain Cotta, Professor, University of Paris Michael 3 Critelli, Chairman, Pitney Bowes, Inc., Stamford Lester Crystal, NBC/RCA Gerald L. Curtis, Prof. Poli Sci, Columbia Univ. Kenneth Dam, U.S. Deputy Secretary of the Treasury Lynn
Entities connected to both U.S. Virgin Islands and Pitney Bowes

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
New York
LOCATION
Alan Dershowitz
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Department of Justice
ORGANIZATIONLeon Black
PERSON
Bradley Edwards
PERSON
Virginia Giuffre
PERSON
Sarah Ferguson
PERSON
Marc Rich
PERSON
Julie K. Brown
PERSON
Lawrence Krauss
PERSON
Prince Charles
PERSON
Michael Jackson
PERSON
George Mitchell
PERSON
New York State
LOCATION