Epstein Secrets

nduct "a particularized review and unseal all documents for which the presumption of public access outweighs any countervailing privacy interests." Brown v. Maxwell, 929 F.3d 41, 51 (2d Cir. 2019). Second, consolidation of the civil and criminal appeals would not further the interests of equity or ju

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

s broad, it is not without limits. Washington v. Brown & Williamson Tobacco, 959 F.2d 1566, 1570 (11th C

other inquiries related to the same subject matter in this case, the related cases and those matters outlined in Epstein's in camera submissions at D.E. #s 282 and 283. Given the allegations raised in the various Complaints and the elements 5 EFTA00592195 Case 9:08-cv-80119-KAM Document 462 Enter

nt for past conduct. See, e.g., United States v. Brown, 381 U.S. 437, 456.462, 85 S.Ct. 1707, 1719-1722,

retrial motions by the parties is March 5, 2010. This action is currently set for trial on the two week calendar commencing Monday, July 16, 2010. [D.E. 119]. Thus, in order to comply with the Court's order, Defendant is filing the subject motion now. As stated above, Defendant requests and reserves

s broad, it is not without limits. Washington 1. Brown & Williamson Tobacco, 959 F.2d 1566, 1570 (11th C

other inquiries related to the same subject matter in this case, the related cases and those matters outlined in Epstein's in camera submissions at D.E. #s 282 and 283. Given the allegations raised in the various Complaints and the elements 5 EFTA00222432 Case 9:08-cv-80119-KAM Document 462 Enter

See supra p. 33. FN 10. See supra n. 2. FN I 1. Defendant's reliance on United States v. Brown, 801 F.2d 352 (8th Cir.1986), is misplaced. In Brown, the Eighth Circuit determined that the defend- ant had breached a cooperation agree- ment, thus permitting the government to prosecute him for the

EPSTEIN upon her, Plaintiff intends to rely exclusively on the statutory damages, rather than those damages which are available at common law. (See D.E. 113). If however, the Court rules that the statutory floor applies only one time, regardless of the number of times EPSTEIN committed an enumerated

by any materials in the record. Accordingly, these assertions of privilege are inadequate. See Bogle. McClure, 332 F.3d 347, 1358 (11th Cir. 2003); Brown' City of Margate, 842 F.Supp. 515, 520 Should the Court allow the Government to assert privilege with regard to any of the materials, the victims w

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