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

ourt." In re "Agent Orange" Prod. Liab. Litig., 821 F.2d 139, 147 (2d Cir. 1987); see also Andover Data Servs., a Div. of Players Computer, Inc. v. Statistical Tabulating Corp., 876 F.2d 1080, 1083 (2d Only after 76 EFTA00095168 Cir. 1989) ("It is well-settled here and elsewhere, for instance, that a Rule 26(c) protecti

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

EFTA00077708 "Agent Orange" Prod. Liab. Litig., 821 F.2d 139, 147 (2d Cir. 1987); see also Andover Data Sows., a Div. of Players Computer, Inc. v. Statistical Tabulating Corp., 876 F.2d 1080, 1083 (2d Cir. 1989) ("It is well-settled here and elsewhere, for instance, that a Rule 26(c) protective order may be overturned or

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

EFTA00039523 "Agent Orange" Prod. Liab. Litig., 821 F.2d 139, 147 (2d Cir. 1987); see also Andover Data Sows., a Div. of Players Computer, Inc. v. Statistical Tabulating Corp., 876 F.2d 1080, 1083 (2d Cir. 1989) ("It is well-settled here and elsewhere, for instance, that a Rule 26(c) protective order may be overturned or

P ("Boies Schiller") to comply with a grand jury subpoena. The application is granted. I. Background A. The Protective Order In September 2015, Virginia L. Giuffre commenced a civil suit against Ghislaine Maxwell, alleging that Maxwell had defamed Giuffre by stating that Giuffre was not the victim of sex crime

A. The Protective Order In September 2015, Virginia L. Giuffre commenced a civil suit against Ghislaine Maxwell, alleging that Maxwell had defamed Giuffre by stating that Giuffre was not the victim of sex crimes perpetrated by, among others, Maxwell and Jeffrey Epstein ("Epstein"). (15-cv- 7433, Dkt. N

und A. The Protective Order In September 2015, Virginia L. Giuffre commenced a civil suit against Ghislai

eason for the Government to carry the firm's water—the moreso because Judge Sweet ruled some months before he died that the intervenors' appeals in Giuffie meant the lawsuit had not "concluded," and so had postponed the day when that contractual obligation kicked in. (15-cv-7433, Dkt. No. 967 at 6.)3 3

only] based on a finding of improvidence, extraordinary circumstances or compelling need." Andover Data Servs., a Div. of Players Computer, Inc. v. Statistical Tabulating Corp., 876 F.2d 1080,1083 (2d Cir. 1989). Moreover, the Second Circuit has held that Martindell applies to the Government, as well as to any other third p

. 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

n iv EFTA00077610 TABLE OF AUTHORITIES Cases Albright v. Oliver, 510 U.S. 266 (1993) Andover Data Servs., a Div. of Players Computer, Inc. v. Statistical Tabulating Corp., Page(s) 152 876 F.2d 1080 (2d Cir. 1989) 106, 119, 149 Arizona v. Youngblood, 488 U.S. 51 (1988) 76 Aronson v. K. Arakelian, Inc., 154 F.2d

. 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

n iv EFTA00039425 TABLE OF AUTHORITIES Cases Albright v. Oliver, 510 U.S. 266 (1993) Andover Data Servs., a Div. of Players Computer, Inc. v. Statistical Tabulating Corp., Page(s) 152 876 F.2d 1080 (2d Cir. 1989) 106, 119, 149 Arizona v. Youngblood, 488 U.S. 51 (1988) 76 Aronson v. K. Arakelian, Inc., 154 F.2d

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

June 26, 2020) 2021 WL 78235 (January 11, 2021) Albright v. Oliver, 510 U.S. 266 (1993) Andover Data Servs., a Div. of Players Computer, Inc. v. Statistical Tabulating Corp., 876 F.2d 1080 (2d Cir. 1989) 76, Arizona v. Youngblood, 488 U.S. 51 (1988) 179 59 141 26, 29 104 84, 103 52 Aronson v. K. Arakelian, Inc