Epstein Secrets

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

nnie Farmer was introduced by her counsel, David Boies, and stated that she was 16 years old when she "

release." 18 U.S.C. § 3142(g). "The weight afforded to each factor under section 3142(g) is within the `special prov- ince' of the district court." Paulin, 335 F. Supp. 3d at 610. At the outset, it should be noted that the Pretrial Services Report, dated July 12, 2019, concludes that: "The defendant

C. § 3142(g). "The weight afforded to each factor under section 3142(g) is within the 'special prov- ince of the district court." United States v. Paulin, 335 F. Supp. 3d 600, 610 (S.D.N.Y. 2018) (quoting United States v. Shaker, 817 F.2d 189, 196 (2d Cir. 1987)). 313 [9] "The rules concerning admi

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

voice not only improves the quality of the process but can also be expected to often benefits to victims."). Ms Its introduced by her counsel, David Boies, and stated that she was 16 years old when she "had the mis- fortune of meeting Jeffrey Epstein [in] New York." 7/15/19 Tr. at 72. Ms. Farmer said

release." 18 U.S.C. § 3142(g). "The weight afforded to each factor under section 3142(g) is within the `special prov- ince' of the district court." Paulin, 335 F. Supp. 3d at 610. At the outset, it should be noted that the Pretrial Services Report, dated July 12, 2019, concludes that: "The defendant

C. § 3142(g). "The weight afforded to each factor under section 3142(g) is within the 'special prov- ince of the district court." United States v. Paulin, 335 F. Supp. 3d 600, 610 (S.D.N.Y. 2018) (quoting United States v. Shaker, 817 F.2d 189, 196 (2d Cir. 1987)). 313 [9] "The rules concerning admi

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

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

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. Paulin, 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.

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

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

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. Paulin, 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.

ited number of emails from the attorneys (see Exs. 6 & 7).3° AUSA- I did not participate in a second meeting with those attorneys and has never met David Boies. (See Ex. 4 at 4). AUSA- I 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 60 EFTA000

United States v. Page, 657 F.3d 126 (2d Cir. 2011) 138, 140, 147 United States v. Pascarella, 84 F.3d 61 (2d Cir. 1996) 165 United States v. Paulin, 445 F.3d 211 (2d Cir. 2006) 165 United States v. Payner, 447 U.S. 727 (1980) 82, 110 United States v. Pena, 932 F. Supp. 2d 464 (S.D.N.Y. 201

rtindell standard. "circ --- it cited 11 times in its argument to both relevant courts. (See (Exs. 8 Instead, the Government issued a subpoena to Boies in connection with its investigation, and made an application to two judges to modify Rule 26(c) protective orders that precluded full compliance

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. Paulin, 445 F.3d 211, 221 (2d Cir. 2006); United States v. Zackson, 12 F.3d 1178, 1182 (2d Cir. 1993). Under this approach, 165 EFTA00095257 uncharged

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. Paulin, 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