Epstein Secrets

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

vidence that is otherwise admissible at trial. Simply put, "[s]tatements providing background are relevant and need not be struck." United States v. Mostafa, 965 F. Supp. 2d 451, 466 (S.D.N.Y. 2013) (citing Mulder, 273 F.3d at 100). Allegations also will not be stricken where they elucidate the circumst

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

vidence that is otherwise admissible at trial. Simply put, "[s]tatements providing background are relevant and need not be struck." United States v. Mostafa, 965 F. Supp. 2d 451, 466 (S.D.N.Y. 2013) (citing Mulder, 273 F.3d at 100). Allegations also will not be stricken where they elucidate the circumst

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

vidence that is otherwise admissible at trial. Simply put, "[s]tatements providing background are relevant and need not be struck." United States v. Mostafa, 965 F. Supp. 2d 451, 466 (S.D.N.Y. 2013) (citing Mulder, 273 F.3d at 100). Allegations also will not be stricken where they elucidate the circumst

. 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

968 F.2d 216 (2d Cir. 1992) 125 United States v. Morgan, 113 F.3d 1230, 1997 WL 268712 (2d Cir. 1997) (unpublished opinion) 45 United States v. Mostafa, 965 F. Supp. 2d 451 (S.D.N.Y. 2013) 242, 243, 247, 262 United States v. Mulder, 273 F.3d 91 (2d Cir. 2001) 241, 242 United States v. Mullens,

. 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

968 F.2d 216 (2d Cir. 1992) 125 United States v. Morgan, 113 F.3d 1230, 1997 WL 268712 (2d Cir. 1997) (unpublished opinion) 45 United States v. Mostafa, 965 F. Supp. 2d 451 (S.D.N.Y. 2013) 242, 243, 247, 262 United States v. Mulder, 273 F.3d 91 (2d Cir. 2001) 241, 242 United States v. Mullens,

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

.Y. 1995) 83 United States v. Moore, 968 F.2d 216 (2d Cir. 1992) 88 United States v. Morgan, 113 F.3d 1230 (2d Cir. 1997) 34 United States v. Mostafa, 965 F. Supp. 2d 451 (S.D.N.Y. 2013) 159, 160, 163, 171 United States v. Mulder, 273 F.3d 91 (2d Cir. 2001) 159 United States v. Mullens, 536

ces Branch of the Bureau of Prisons, dated August 24th 2020 and the Fourth Supplemental Declaration o Assistant United States Attorney, Alexandria, Virginia, dated September 3nd 2020. I was asked to provide my expert opinion as someone who worked many years in the same federal prison system as Dr I wil

nce with the BOP, especially my time spent as Warden at MCC New York, I find her descriptive account of what life has been like for her client, Mr. Mostafa to be believable and credible. 26. I arrived to MCC New York in 2014, after being promoted to Senior Executive Service Warden from my former posit