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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
erations validly before a jury, and finally, as a remedy designed to deter illegal conduct.' Coke, 2011 WL 3738969, at *6 (quoting United States v. Hastings, 461 U.S. 499, 505 (1983)). "However, while there are times when a district court may properly find it absolutely necessary[, in order] to preserve
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
ore a jury, and finally, as a remedy 109 EFTA00077741 designed to deter illegal conduct.' Coke, 2011 WL 3738969, at '6 (quoting United States v. Hastings, 461 U.S. 499, 505 (1983)). "However, while there are times when a district court may properly find it absolutely necessary[, in order] to preserve
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
ore a jury, and finally, as a remedy 109 EFTA00039556 designed to deter illegal conduct.' Coke, 2011 WL 3738969, at '6 (quoting United States v. Hastings, 461 U.S. 499, 505 (1983)). "However, while there are times when a district court may properly find it absolutely necessary[, in order] to preserve
. 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
978) 216 United States v. Haqq, 278 F.3d 44 (2d Cir. 2002) 115 United States v. Harrison, 764 F. Supp. 29 (S.D.N.Y. 1991) 72 United States v. Hastings, 461 U.S. 499 (1983) 160 United States v. Heath, 455 F.3d 52 (2d Cir. 2006) 132, 133 United States v. Henderson, 337 F.3d 914 (7th Cir. 2003)
. 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
978) 216 United States v. Haqq, 278 F.3d 44 (2d Cir. 2002) 115 United States v. Harrison, 764 F. Supp. 29 (S.D.N.Y. 1991) 72 United States v. Hastings, 461 U.S. 499 (1983) 160 United States v. Heath, 455 F.3d 52 (2d Cir. 2006) 132, 133 United States v. Henderson, 337 F.3d 914 (7th Cir. 2003)
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
1978) 144 United States v. Haqq, 278 F.3d 44 (2d Cir. 2002) 82 United States v. Harrison, 764 F. Supp. 29 (S.D.N.Y. 1991) 50 United States v. Hastings, 461 U.S. 499 (1983) 109 United States v. Heath, 455 F.3d 52 (2d Cir. 2006) 93, 94 United States v. Henderson, 337 F.3d 914 (7th Cir. 2003) 4
irl in Cairnbrook, Pennsylvania, took her to West Virginia and assaulted her before releasing the child."
r the parents are being reunified." Border Patrol Chief of Operations Brian Hastings: "Yes." Nadler: "In other words, you're kidnapping the child." Hastings: "Not kidnapping the child." Nadler: "Taking a parent without their child is kidnapping." NBC (Bennett) added, "The Trump Administration is still un
Office of Special Counsel for the investigation of U.S. Secretary of Commerce Ronald Brown; the U.S. Attorney's Office for the Eastern District of Virginia; and the U.S. Attorney's Office of the District of Maryland, where he served as the Chief of the Appellate Division. After leaving federal service,
ivate parties or the general public." Sells Engineering, 463 U.S. at 445; see hr re Request for Access to Grand Jury Materials Grand Jury No. 81-1 (Hastings), 833 F.2d 1438, 1441 (11°1Cir. 1987) ("the interests that underlie the policy of grand jury secrecy affected implicated to a lesser degree when dis
rneys, Seattle Oklahoma County Bar Assn, Oklahoma City Connecticut Trial Lawyers Assn, Hartford Judge Advocate General's School, Charlottesville, Virginia Law Society of Upper Canada, Toronto Florida Bar Assn, Tampa and Miami Bolt, Beranek & Newman, Cambridge Colloquium on New Ways of Analyzing Var
r, C. (Eds) (2013) Knowledge Evolved: Psychology Edition. Noba (online textbook: http://nobaproject.com/) Lewandowsky, S., Mann, M. E., Bauld, L., Hastings, G., & Loftus, E. F. (2013, November 1). The subterranean war on science. APS Observer, online only. Retrieved from: htto://www.osvchologicalscienc
share for an independent or third-party bid since Theodore Roosevelt and ultimately contributing to Bill Clinton's victory. (Donald P. Baker) 2. Virginia's GOP-controlled General Assembly ended a special session on gun legislation after about 90 minutes. The Virginia Senate voted along party lines to
f the motivation of legacy media companies embracing subscription streaming services is to capture some of Netflix's valuation — or bring CEO Reed Hastings' behemoth back down to earth." SOCIAL MEDIA SPEED READ: Page 12558 EFTA00043069 One of Trump's senior advisers mocked the House speaker's confl
Entities connected to both Virginia Giuffre and Hastings

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
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
Stephen Hawking
PERSON
Prince Charles
PERSON