Epstein Secrets

y, as well as similar compensation funds for the Dioceses of Brooklyn and Rockville Centre, New York and for Dioceses in the states of California, Colorado, New Jersey and Pennsylvania. • Mr. Feinberg has served as adjunct professor of law at Harvard Law School, Columbia Law School, University of Penn

niversity of Virginia School of Law, and Benjamin N. Cardozo School of Law. Before his academic career, he served as an Assistant U.S. Attorney for the Southern District of New York, special counsel for the U.S. Senate Committee on the Judiciary, and founding partner of the Washington office of the law firm Kaye Scholer LLP, am

esented the case to the U.S. Attomey’s Office for the Southern District of Florida. In 2007, the Office contacted counsel

rights even before prosecutors filed a superseding indictment covering the specific crimes affecting the victims. Citing Dean, the District Court for the Eastern District of New York agreed that the rights were expansive and could apply before charges were filed but were subject to the outer limit that the Government has at least

2. HOUSE_OVERSIGHT_014078 --- PAGE BREAK --- 100 CASSELL ET AL. [Vol. 104 Other states also expressly extend nights before the filing of charges. Colorado guarantees rights at “all critical stages of the criminal justice process|,]” which includes both the filing of charges and the decision to not file

lorado. 7. Defendant Maxwell, who is domiciled in the Southern District of New York, is not a citizen of the state of Col

E BREAK --- Case 1:15-cv-07433 Document1 Filed 09/21/15 Page 3 of 12 PARTIES 6. Plaintiff Giuffre is an individual who is a citizen of the State of Colorado. 7. Defendant Maxwell, who is domiciled in the Southern District of New York, is not a citizen of the state of Colorado. FACTUAL ALLEGATIONS 8. Virgi

fre’s factual assertions as “entirely false” and “entirely untrue.” 32. Maxwell made the same false and defamatory statements as set forth above, in the Southern District of New York and elsewhere in a deliberate effort to maliciously discredit Giuffre and silence her efforts to expose sex crimes committed around the world by Maxw

sented the case to the U.S. Attorney's Office for the Southern District of Florida. In 2007, the Office contacted counsel

ights even before prosecutors filed a superseding indictment covering the specific crimes affecting the victims. Citing Dean, the District Court for the Eastern District of New York agreed that the rights ® John W. Gillis & Douglas E. Beloof, The Next Step for a Maturing Victim Rights Movement: Enforcing Crime Victim Rights in t

d a possible consultation right long before formal charges are filed. [*100] Other states also expressly extend rights before the filing of charges. Colorado guarantees rights at "all critical stages of the criminal justice process[,]" which includes both the filing of charges and the decision to not file

212-957-7600 Jeffrey S. Pagliuca (pro hac vice admission pending) Laura A. Menninger HADDON, MORGAN & FORMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: 303-831-7364 Attorneys for Ghislaine Maxwell EFTA00018515 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Pag

d States v. Crowell, No. 06-CR-29IE(F), 2006 WL 3541736 (W.D.N.Y. Dec. 7, 2006) 11 United States v Deutsch, No. 18-CR-502 (FB), 2020 WL 3577398 (E.D.N.Y. July 1, 2020) 11, 18 United States v. DiGiacomo, 746 F. Supp. 1176 (D. Mass. 1990) 14 United States v Dominguez, 783 F.2d 702 (7th Cir. 1986

ed several civil 12 EFTA00018530 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 17 of 26 cases related to Epstein in the Southern District of New York and has sat for depositions in those cases. Similarly, throughout the course of the criminal investigation of this case, which has been publicly re

s sexual trafficking victims in a case pending in the Southern District of Florida, specifically case no. 08-cv-80736- KA

o do with this Florida Defamation Action; rather, he is trying to find a way to send this victim of sexual trafficking to “Jail.” “She was hiding in Colorado...but we found her and she will have to be deposed. The end * For the limited purpose of the Motion to Quash or for Protective Order and resolving t

g to challenge those decisions. '24 A few [*882] limited exceptions prove the rule. In cases of private criminal complaints filed by alleged victims, Colorado, Michigan, Nebraska, and Pennsylvania authorize judges to review public prosecutors' decisions not to charge. !?> Even when statutes grant courts the

onvincing Congress to expand their discretion at the expense of judges' sentencing authority, see United States v. Kupa, 976 F. Supp. 2d 417, 419-27 (E.D.N.Y. 2013) (describing the legislative history and Justice Department lobbying related to federal drug statutes, notably 27 U.S.C. § 841 (2012)). 218 See

o-counsel Robert Hoyt, Arnon Siegel, and Karan Bhatia of the Washington, D.C. law firm of Wilmer, Cutler, and Pickering, and Sean Kendall of Boulder, Colorado. 30 42 U.S.C. 10606(b)(4) (1994) (repealed 2004). The victims also relied on a similar provision found in the authorization for closed circuit broad

rious crimes the right to restitution. *°* Reinforcing those laws, the CVRA guarantees that victims have "the right 43 Magistrate Judge Orenstein of the Eastern District of New York, who has written many thoughtful opinions on the CVRA, has taken a contrary position. See Report and Recommendation, United States v. Ingrassis, No.

a citizen of the State of Colorado. 7. Defendant Maxwell, who is domiciled in the Southern District of New York, is not a citizen of the state of Colorado. FACTUAL ALLEGATIONS 8. became a victim of sex trafficking and repeated sexual abuse after being recruited by Ghislaine Maxwell and Jeffrey Epste

forts made by Epstein and other powerful persons acting as Epstein's representatives and surrogates. Maxwell made and coordinated her statements in the Southern District of New York and elsewhere with the specific intent to amplify the defamatory effect those statements would have on reputation and credibility. 17. Maxwell ma

d the victims who are here today, among others, for your very hard work and dedication in this case. We also have here today the U.S. Attorney for the Southern District of New York, Geoffrey Berman, who has also been very helpful and indispensable in this matter. The news on August 10, 2019, that Jeffrey Epstein had been foun

e questions that my co-counsel did, you know, was the dysfunction of the critical pivotal video, in the most secure prison east of Florence, out in Colorado known to the MCC before August 10, or was this corruption occurring on August 10, which would again cause us to be skeptical of the servitude of t