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. Mot. 7 at 16). She again cites the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obtain materials from the Giuffre civil litigation. (Id.). Leaving aside the fact that, as set forth in Section IV, the Government obtained such materials through a judicially approv
inner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards p
oies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards provided AUSA-1 wi
r. 2019) 154 United States v. Cromitie, et al., 09 Cr. 558 (CM) 286 United States v. Crouch, 84 F.3d 1497 (5th Cir. 1996) 75 United States v. D'Amico, 734 F. Supp. 2d 321 (S.D.N.Y. 2010) 268 United States v. Davis, 702 F.2d 418 (2d Cir. 1983) passim United States v. DeFilippo, No. 17 Cr. 585
. Mot. 7 at 16). She again cites the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obtain materials from the Giuffre civil litigation. (Id.). Leaving aside the fact that, as set forth in Section IV, the Government obtained such materials through a judicially approv
inner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards p
oies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards provided AUSA-1 wi
r. 2019) 154 United States v. Cromitie, et al., 09 Cr. 558 (CM) 286 United States v. Crouch, 84 F.3d 1497 (5th Cir. 1996) 75 United States v. D'Amico, 734 F. Supp. 2d 321 (S.D.N.Y. 2010) 268 United States v. Davis, 702 F.2d 418 (2d Cir. 1983) passim United States v. DeFilippo, No. 17 Cr. 585
side, the civil matters were in completely different procedural postures, which implicate different concerns regarding a pending criminal case. The Giuffre v. Maxwell litigation was settled and complete well before the Government even opened its investigation in this case. By contrast, the Doe v. Indyk
inner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards p
oies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards provided AUSA-1 wi
) 40, 41 United States v. Cromitie, 727 F.3d 194 (2d Cir. 2019) 106 United States v. Crouch, 84 F.3d 1497 (5th Cir. 1996) 52 United States v. D'Amico, 734 F. Supp. 2d 321 (S.D.N.Y. 2010) 176 United States v. Davis, 702 F.2d 418 (2d Cir. 1983) 78, 81, 103 United States v. DeFilippo, No. 17 Cr
S. Attorney's Office for the Eastern District of Virginia"); Gonzalez, 93 F. App'x at 270 ("Paragraph 13 ex
Co., 583 F. Supp. 197 (D.S.C.), affd, 749 F.2d 33 (4th Cir. 1984) 16 United States v. Clements, 992 F.2d 417 (2d Cir. 1993) 15 United States v. D'Amico, 734 F. Supp. 2d 321 (S.D.N.Y. 2010) 21 United States v. El-Sadig, 133 F. Supp. 2d 600 (N.D. Ohio 2001) 17 United States v. Feldman, 939 F.3d
S. Attorney's Office for the Eastern District of Virginia"); Gonzalez, 93 F. App'x at 270 ("Paragraph 13 ex
Co., 583 F. Supp. 197 (D.S.C.), affd, 749 F.2d 33 (4th Cir. 1984) 16 United States v. Clements, 992 F.2d 417 (2d Cir. 1993) 15 United States v. D'Amico, 734 F. Supp. 2d 321 (S.D.N.Y. 2010) 21 United States v. El-Sadig, 133 F. Supp. 2d 600 (N.D. Ohio 2001) 17 United States v. Feldman, 939 F.3d
Microsoft Word - 2017.03.16 Deft Resp IO to Ptfs Omnibus Motn in Limine (MASTER).docx
T SOUTHERN DISTRICT OF NEW YORK wn eee ee eee xX VIRGINIA L. GIUFFRE, Plaintiff, Vv. 15-cv-07433-RWS GHISLAINE MAXW
Page: HOUSE_OVERSIGHT_014788 →T SOUTHERN DISTRICT OF NEW YORK wn eee ee eee xX VIRGINIA L. GIUFFRE, Plaintiff, Vv. 15-cv-07433-RWS GHI
Page: HOUSE_OVERSIGHT_014788 →ISTRICT OF NEW YORK wn eee ee eee xX VIRGINIA L. GIUFFRE, Plaintiff, Vv. 15-cv-07433-RWS GHISLAINE MAXW
Page: HOUSE_OVERSIGHT_014788 →t 749 Filed 03/17/17 Page 5 of 9 Jaffee v. Redmond, 518 U.S. 1, 116 S.Ct. 1923, 135 L.Ed.2d 337 (1996) oo... cece eeeeees 22 Kadant Johnson Inc. v. D'Amico, No. CIV.A. 10-2869, 2012 WL 2190897, at *1 (E.D. La. June V4, 2012) ooo ccc ccceccseccscecsscsecseseeeeseessecssecssesseeseeeessscsaecseesseeessecsa
Page: HOUSE_OVERSIGHT_014792 →Entities connected to both Virginia Giuffre and D'Amico

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATION
George W. Bush
PERSON
United States
LOCATIONLeon Black
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Julie K. Brown
PERSON
New York
LOCATIONthe Southern District
LOCATIONMaria Farmer
PERSON
Colorado
LOCATIONFBI
ORGANIZATION
Scarlett Johansson
PERSON
Michael Jackson
PERSON
George Mitchell
PERSONEmmy Taylor
PERSON
Michigan
LOCATION