Epstein Secrets

endant, both in New York and in Florida." Dkt. I I, Ex. I at 2. 26 EFTA00039408 Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 27 of 33 David Boies, who, as noted, represents identified victims in this case, advised the Court that while a civil case was proceeding against the Defendant "we had s

B Document 32 Filed 07/18/19 Page 27 of 33 David Boies, who, as noted, represents identified victims in

.S.C. § 3I42(g). "The weight afforded to each factor under section 3142(g) is within the `special province' of the district court." United States v. Paulino, 335 F. Supp. 3d 600, 610 (S.D.N.Y. 2018) (quoting United States v. Shakur, 817 F.2d 189, 196 (2d Cir. 1987)). "The rules concerning admissibility

improves the quality of the process but can also be expected to often provide important benefits to victims."). Ms. -was introduced by her counsel, David Boies, and stated that she was 16 years old when she "had the misfortune of meeting Jeffrey Epstein [in] New York." 7/15/19 Tr. at 72. Ms. Farmer said th

ms."). Ms. -was introduced by her counsel, David Boies, and stated that she was 16 years old when she "

.S.C. § 3I42(g). "The weight afforded to each factor under section 3142(g) is within the `special province' of the district court." United States v. Paulino, 335 F. Supp. 3d 600, 610 (S.D.N.Y. 2018) (quoting United States v. Shakur, 817 F.2d 189, 196 (2d Cir. 1987)). "The rules concerning admissibility

fendant, both in New York and in Florida." Dkt. 11, Ex. I at 2. 26 EFTA00074054 Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 27 of 33 David Boies, who, as noted, represents identified victims in this case, advised the Court that while a civil case was proceeding against the Defendant "we had s

B Document 32 Filed 07/18/19 Page 27 of 33 David Boies, who, as noted, represents identified victims in

.S.C. § 3I42(g). "The weight afforded to each factor under section 3142(g) is within the `special province' of the district court." United States v. Paulino, 335 F. Supp. 3d 600, 610 (S.D.N.Y. 2018) (quoting United States v. Shakur, 817 F.2d 189, 196 (2d Cir. 1987)). "The rules concerning admissibility

mited number of emails from the attorneys (see Exs. 6 & 7).30 AUSA-1 did not participate in a second meeting with those attorneys and has never met David Boies. (See Ex. 4 at 4). AUSA-1 recalls being aware of depositions as a general matter, but she does not recall having knowledge of who had been deposed

ges, based on a New York Daily News article, that Boies Schiller and the Government colluded starting in

United States v. Page, 657 F.3d 126 (2d Cir. 2011) 205,209,210,220 United States v. Pascarella, 84 F.3d 61 (2d Cir. 1996) 252 United States v. Paulino, 445 F.3d 211 (2d Cir. 2006) 253 United States v. Payner, 447 U.S. 727 (1980) 115, 161, 162 United States v. Pena, 932 F. Supp. 2d 464 (S.D.N.

Boies it was issued. The materials provided by Boies Schiller inclnin addition tIl inscripts of Maxwell and other individuals, materials proday N/14!I

ot. 3, Ex. D at 17). In support of her argument, Maxwell cites again to the Daily News Article, which reports that "after Maxwell's two depositions, David Boies himself apparently approached the government in the summer of 2016, asking `if the Southern District would consider charging Maxwell with perjury' (

relevant under Fed. R. Evid. 402." United States v. Pascarella, 84 F.3d 61, 69 (2d Cir. 1996) (internal citation omitted); see also United States v. Paulino, 445 F.3d 211, 221 (2d Cir. 2006); United States v. Zackson, 12 F.3d 1178, 1182 (2d Cir. 1993). Under this approach, uncharged acts are admissible

ot. 3, Ex. D at 17). In support of her argument, Maxwell cites again to the Daily News Article, which reports that "after Maxwell's two depositions, David Boies himself apparently approached the government in the summer of 2016, asking if the Southern District would consider charging Maxwell with perjury"' (

y contrast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. A

relevant under Fed. R. Evid. 402." United States v. Pascarella, 84 F.3d 61, 69 (2d Cir. 1996) (internal citation omitted); see also United States v. Paulino, 445 F.3d 211, 221 (2d Cir. 2006); United States v. Zackson, 12 F.3d 1178, 1182 (2d Cir. 1993). Under this approach, uncharged acts are admissible

ot. 3, Ex. D at 17). In support of her argument, Maxwell cites again to the Daily News Article, which reports that "after Maxwell's two depositions, David Boies himself apparently approached the government in the summer of 2016, asking if the Southern District would consider charging Maxwell with perjury"' (

y contrast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. A

relevant under Fed. R. Evid. 402." United States v. Pascarella, 84 F.3d 61, 69 (2d Cir. 1996) (internal citation omitted); see also United States v. Paulino, 445 F.3d 211, 221 (2d Cir. 2006); United States v. Zackson, 12 F.3d 1178, 1182 (2d Cir. 1993). Under this approach, uncharged acts are admissible

gain cites the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obta

mited number of emails from the attorneys (see Exs. 6 & 7).30 AUSA-1 did not participate in a second meeting with those attorneys and has never met David Boies. (See Ex. 4 at 4). AUSA-1 recalls being aware of depositions as a general matter, but she does not recall having knowledge of who had been deposed

ited States v. Page, 657 F.3d 126 (2d Cir. 2011) 205, 209, 210, 220 United States v. Pascarella, 84 F.3d 61 (2d Cir. 1996) 252 United States v. Paulino, 445 F.3d 211 (2d Cir. 2006) 253 United States v. Payner, 447 U.S. 727 (1980) 115, 161, 162 United States v. Pena, 932 F. Supp. 2d 464 (S.D.N.