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That investigation was opened more than two and a half years after the last known contact between any lawyer associated with any civil counsel for Giuffre and, in any event, was initially focused on Epstein, not this defendant. As detailed above, the USAO-SDNY opened the instant investigation in late
.F.L). See generally Doe No. 1. v. United States, 749 F.3d 999, 1002 (11th Cir. 2014) (describing the background of the suit). On December 30, 2014, Virginia Roberts Giuffre moved to join the petition, alleging that the USAO-SDFL had also violated her CVRA rights. See Doe, No. 08 Civ. 80736, Dkt. No. 279.45 the9 "one of
t persons, people under the age of 18. A. I looked for people or tried to find people to fill professional jobs in professional situations. Q. So Virginia Roberts was under the age of 18, correct? A. I think we've established that Virginia was 17. Q. Is she the -- sorry, go ahead. Is she the only individual t
e to fill professional jobs in professional situations. Q. So Virginia Roberts was under the age of 18, correct? A. I think we've established that Virginia was 17. Q. Is she the -- sorry, go ahead. Is she the only individual that you met for purposes of hiring someone for Jeffrey that was under the ag
No. 542-4). Giuffre has since self-identified as Jane Doe #3. (See id., Dkt. No. 23 n.2). 117 EFTA00095209
se questions-for instance that Epstein in fact had a scheme to recruit underaged girls for sexual massages—would have been corroborative of some of Giuffre's claims. Second, had the defendant honestly answered the deposition questions, Giuffre could have located other victims or witnesses who may have cor
or can a conviction rest on answers that are literally true but unresponsive, and therefore "arguably misleading by negative implication." Id.; see Bronston v. United States, 409 U.S. 352, 362 (1973). But when "the answer is false, the fact that it is unresponsive is immaterial." United States v. Corr, 5
that standard." (Id. at 7) (emphasis in original). 8. Unsealing of Maxwell's Depositions Three months after Chief Judge McMahon issued her Order, Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain liti
.F.L). See generally Doe No. 1. v. United States, 749 F.3d 999, 1002 (11th Cir. 2014) (describing the background of the suit). On December 30, 2014, Virginia Roberts Giuffre moved to join the petition, alleging that the USAO-SDFL had also violated her CVRA rights. See Doe, No. 08 Civ. 80736, Dkt. No. 279.45 In her motion
t persons, people under the age of 18. A. I looked for people or tried to find people to fill professional jobs in professional situations. Q. So Virginia Roberts was under the age of 18, correct? A. I think we've established that Virginia was 17. Q. Is she the -- sorry, go ahead. Is she the only individual t
e to fill professional jobs in professional situations. Q. So Virginia Roberts was under the age of 18, correct? A. I think we've established that Virginia was 17. Q. Is she the -- sorry, go ahead. Is she the only individual that you met for purposes of hiring someone for Jeffrey that was under the ag
se questions-for instance that Epstein in fact had a scheme to recruit underaged girls for sexual massages—would have been corroborative of some of Giuffre's claims. Second, had the defendant honestly answered the deposition questions, Giuffre could have located other victims or witnesses who may have cor
or can a conviction rest on answers that are literally true but unresponsive, and therefore "arguably misleading by negative implication." Id.; see Bronston v. United States, 409 U.S. 352, 362 (1973). But when "the answer is false, the fact that it is unresponsive is immaterial." United States v. Corr, 5
that standard." (Id. at 7) (emphasis in original). 8. Unsealing of Maxwell's Depositions Three months after Chief Judge McMahon issued her Order, Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain liti
.F.L). See generally Doe No. 1. v. United States, 749 F.3d 999, 1002 (11th Cir. 2014) (describing the background of the suit). On December 30, 2014, Virginia Roberts Giuffre moved to join the petition, alleging that the USAO-SDFL had also violated her CVRA rights. See Doe, No. 08 Civ. 80736, Dkt. No. 279.45 In her motion
t persons, people under the age of 18. A. I looked for people or tried to find people to fill professional jobs in professional situations. Q. So Virginia Roberts was under the age of 18, correct? A. I think we've established that Virginia was 17. Q. Is she the -- sorry, go ahead. Is she the only individual t
e to fill professional jobs in professional situations. Q. So Virginia Roberts was under the age of 18, correct? A. I think we've established that Virginia was 17. Q. Is she the -- sorry, go ahead. Is she the only individual that you met for purposes of hiring someone for Jeffrey that was under the ag
se questions-for instance that Epstein in fact had a scheme to recruit underaged girls for sexual massages—would have been corroborative of some of Giuffre's claims. Second, had the defendant honestly answered the deposition questions, Giuffre could have located other victims or witnesses who may have cor
or can a conviction rest on answers that are literally true but unresponsive, and therefore "arguably misleading by negative implication." Id.; see Bronston v. United States, 409 U.S. 352, 362 (1973). But when "the answer is false, the fact that it is unresponsive is immaterial." United States v. Corr, 5
Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is so not a new individual. The allegations made by against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully
also United States v. Bonacorsa, 528 F.2d 1218, 1221 (2d Cir. 1976). "Precise questioning is imperative as a predicate for the offense of perjury." Bronston v. United States, 409 U.S. 352, 362 (1973). "A question is fundamentally ambiguous when it is not a phrase with a meaning about which men of ordina
2012), is instructive: Succinctly, the prosecutor did not fulfill her obligation to "pin the witness down to the specific object of [her] inquiry." Bronston, 409 U.S. at 360. Any number of straightforward follow-up questions could have clarified the object of inquiry. For example, in addition to the "at
6 III. The Questions and Answers Were Immaterial 10 CONCLUSION 10 Certificate of Service 12 i EFTA00097379 TABLE OF AUTHORITIES Cases Bronston v. United States, 409 U.S. 352 (1973) 6, 7, 10 v. Maxwell, 325 F. Supp. 3d 428 (S.D.N.Y. 2018) 1 United States v. Bonacorsa, 528 F.2d 1218 (2d C
. 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
Boyd v. United States, 116 U.S. 616 (1886) 145 Branzburg v. Hayes, 408 U.S. 665 (1972) 110 Bridges v. United States, 346 U.S. 209 (1953) 53 Bronston v. United States, 409 U.S. 352 (1973) 181 Bryson v. United States, 396 U.S. 64 (1969) 147 Burgess v. United States, 552 U.S. 124 (2008) 51 C
. 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
Boyd v. United States, 116 U.S. 616 (1886) 145 Branzburg v. Hayes, 408 U.S. 665 (1972) 110 Bridges v. United States, 346 U.S. 209 (1953) 53 Bronston v. United States, 409 U.S. 352 (1973) 181 Bryson v. United States, 396 U.S. 64 (1969) 147 Burgess v. United States, 552 U.S. 124 (2008) 51 C
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
ates, 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 v. United States, 396 U.S. 64 (1969) 101 Burgess v. United States, 552 U.S. 124 (2008) 37 C
Suspect in Deputy Death Escapes Jail; Unnoticed for 26 Hours The Associated Press (05/02, Staff Writer) reported that two men escaped from a jail in Virginia over the weekend, including one charged in the killing of a North Carolina sheriff's deputy last year. Alder Marin-Sotelo, 26, escaped from Piedmon
ng to the discovery of a safe containing fireworks and wires. The article noted that the investigation involves the Harvard University police, FBI's Boston- area Joint Terrorism Task Force, and ongoing efforts to identify other individuals involved in the conspiracy. Back to Top COUNTERINTELLIGENCE Eva
Jun 2016, | Somew 339 | negative global celeb in Britain ag #Brexit. Follow the $> 05:13 - CEST | herein globalization great for them, horrid fora€ | Virginia KostJason RT @MikeMacck: Be a patriot. Vote Leave. #Brexit 23 Jun 2016, | Astoria, 3 | positive https://t.co/KhOnHwoWkxX 05:30-CEST | OR funfreefun 4
1:14 -CEST | Mersea, How can you vote for a cause with no plan or idea England HelleNico "Making Sense of a€~Brexita€™ in 4 Charts" by 23 Jun 2016, | Boston 0 | neutral AMANDA TAUB via NYT The New York Times 11:14 - CEST https://t.co/isua5Hfoxu 24Espana Brexit: GuAa para seguir y no perderse nada en la 23 J
who sex offender friend flew to Britain to meet him I Mail On...Page 2 of 17 . , • • First meeting: Prince Andrew puts his arms around 17-yearcid Virginia, centre On one of those occasions ,MI was subsequently paid $15,000 (O,400). Her shocking account of her four years as pste n s personal masseuse
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Entities connected to both Virginia Giuffre and Boston

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Donald Trump
PERSON
Department of Justice
ORGANIZATION
George W. Bush
PERSON
United States
LOCATION
Alan Dershowitz
PERSONLeon Black
PERSON
Bradley Edwards
PERSON
Bill Clinton
PERSONJane Doe
PERSON
Julie K. Brown
PERSON
New York
LOCATION
Joe Biden
PERSONthe Southern District
LOCATION
Marc Rich
PERSONMaria Farmer
PERSON
Prince Charles
PERSON
Stephen Hawking
PERSON