Epstein Secrets

Ghislaine Maxwell's Appendix is cited as "App." Virginia Giuffre's Supplemental Appendix is cited as "SA." EFTA0009

rt's September 11, 2020, order directing the parties to respond to the Government's amicus letter brief filed on September 16, 2020. D.E. 113.1 Ms. Giuffre agrees with the Government's position and opposes Defendant's motion to consolidate this appeal (the "civil appeal") with her appeal in United Stat

States Court of Appeals for the Second Circuit VIRGINIA L GIUFFRE, —against- GHISLAINE MAXWELL, Plainti

ant to this Court's September 11, 2020, order directing the parties to respond to the Government's amicus letter brief filed on September 16, 2020. D.E. 113.1 Ms. Giuffre agrees with the Government's position and opposes Defendant's motion to consolidate this appeal (the "civil appeal") with her app

criminal appeals bearing no relation to one another. First, the issues presented in the criminal appeal have no bearing on the civil Citations to "D.E." refer to this Court's docket. Ghislaine Maxwell's Appendix is cited as "App." Virginia Giuffre's Supplemental Appendix is cited as "SA." EFTA00095

lleged by petitioners, then there is no good explanation for why they waited two years to attempt to add her to this lawsuit. III. THE ADDITION OF JANE DOE #3 AND JANE DOE #4 WILL PREJUDICE THE GOVERNMENT The Government disagrees with petitioners' assertion that the addition of the two new victims will n

ates: I. PETITIONERS' MOTION TO ADD TWO ADDITIONAL PARTIES SHOULD BE DENIED AS UNTIMELY This action was commenced by Jane Doe #1 on July 7, 2008 (D.E. I). The Court ordered the Government to file a response by July 9, 2008, which was done. On July 11, 2008, the Court held a hearing on the emergenc

Section Chief at FBI Headquarters, Washington, D.C. I was appointed a Special Agent in May 1999. Upon graduation from the FBI Academy at Quantico, Virginia, in September 1999, I was assigned to the Detroit Field Office. I was subsequently transferred to the FBI Miami Field Office in May 2006. 2. In 20

the person whom Petitioners refer to as "Jane Doe 5" also had been approached by the investigative team in 2007 but refused to speak with them. (See D.E. 14 at 1 3.) Regardless of the perceived strength of the corroborating evidence, it was and remains my professional opinion as an experienced prosec

opold, Esquire Leopold, Kuvin, P.A. 2925 P.G.A. Boulevard, Suite 200 Palm Beach Gardens, FL 33410 Tel: Subject matter: Victim of Epstein. 12. Jane Doe #7 (Case No.: 9:08-cv-80993-KAM) cto her attorney: Jeffrey ht Herman, Esquire Herman & Mermelstein, P.A. 7 EFTA00182966 Case 9:08-cv-80119-KAM D

s extended. In light of Plaintiffs filing of her Conditional Notice of Intent to Exclusively Rely on Statutory Damages Provided by 18 U.S.C. §2255 (D.E. 113) on June 5, 2009, Plaintiff agrees to a modification of the pretrial schedule as outlined in Defendant EPSTEIN's Motion to Strike (D.E. 104); to

STATES RESPONSE: 2. (a) The government admits that, after Epstein's attorneys learned of the notification that the government planned to provide to Jane Doe #2, who claimed that she was not a victim, Epstein's attorneys contacted the USAO and objected to the procedures for notification and the legal bases

vilege log with its objections annotated (D.E. 224-1); (2) a motion to compel production of documents that are not privileged, numbering eight pages D.E. 225; (3) a twenty-four page, single-spaced affidavit of petitioners' counsel, addressing the EFTA00179785 Case 9:08-cv-80736-KAM Document 230 Ent