I. The Government's Response to Maxwell's Motion. Confronted with evidence of AUSA misrepresentations to Judge McMahon, the government has filed a Response reluctantly admitting that the U.S. Attorney's Office had sustained contact with Boies Schiller in 2016. Even so, the government tries its best to m

(DEI at 1-2.) On the same day, the government was ordered by the Court to respond. (DE3). Two days later, on July 9, 2008, the Government filed its Response and an accompanying Declaration, establishing that (1) no federal criminal case charging Epstein had ever been filed and that a non- prosecution agr

constitutes an impermissible constructive amendment and variance to the Indictment. Finally, what is clear from the government's proffer in their Response, the anticipated testimony o will serve as an improper constructive 13 EFTA00090739 amendment to, and an impermissible variance of, the Indictm

the court, the use of the qualifier made the question fundamentally ambiguous requiring dismissal of the count. The government, at page 133 of its Response, incorrectly suggests that the burden was on Ms. Maxwell or her counsel to clarify the confused questions, particularly regarding the infinite time

attention to page 5 of the joint letter, in which Menninger wrote: Indeed, this Court rejected Ms. Maxwell's argument that certain portions of the Response and its exhibits should be unredacted because the material had already been made public. See Dkt. No. 168 at 2-3; Letter Motion of Laura A. Menning

(DEI at 1-2.) On the same day, the government was ordered by the Court to respond. (DE3). Two days later, on July 9, 2008, the Government filed its Response and an accompanying Declaration, establishing that (1) no federal criminal case charging Epstein had ever been filed and that a non- prosecution agr

(DE1 at 1-2.) On the same day, the government was ordered by the Court to respond. (DE3). Two days later, on July 9, 2008, the Government filed its Response and an accompanying Declaration, establishing that (1) no federal criminal case charging Epstein had ever been filed and that a non-prosecution agre

r. Epstein has no interest in keeping the agreement confidential because he has not responded to Mr. Edwards' motion to unseal. As you know, in our Response, the United States argued that this issue should be litigated in one of the suits filed by Mr. Edwards against Mr. Epstein. Mr. Edwards apparently b

r. Epstein has no interest in keeping the agreement confidential because he has not responded to Mr. Edwards' motion to unseal. As you know, in our Response, the United States argued that this issue should be litigated in one of the suits filed by Mr. Edwards against Mr. Epstein. Mr. Edwards apparently b

r. Epstein has no interest in keeping the agreement confidential because he has not responded to Mr. Edwards' motion to unseal. As you know, in our Response, the United States argued that this issue should be litigated in one of the suits filed by Mr. Edwards against Mr. Epstein. Mr. Edwards apparently b

r. Epstein has no interest in keeping the agreement confidential because he has not responded to Mr. Edwards' motion to unseal. As you know, in our Response, the United States argued that this issue should be litigated in one of the suits filed EFTA00215970 by Mr. Edwards against Mr. Epstein. Mr. Edwar

r. Epstein has no interest in keeping the agreement confidential because he has not responded to Mr. Edwards' motion to unseal. As you know, in our Response, the United States argued that this issue should be litigated in one of the suits filed by Mr. Edwards against Mr. Epstein. Mr. Edwards apparently b

r. Epstein has no interest in keeping the agreement confidential because he has not responded to Mr. Edwards' motion to unseal. As you know, in our Response, the United States argued that this issue should be litigated in one of the suits filed by Mr. Edwards against Mr. Epstein. Mr. Edwards apparently b

r. Epstein has no interest in keeping the agreement confidential because he has not responded to Mr. Edwards' motion to unseal. As you know, in our Response, the United States argued that this issue should be litigated in one of the suits filed by Mr. Edwards against Mr. Epstein. Mr. Edwards apparently b

r. Epstein has no interest in keeping the agreement confidential because he has not responded to Mr. Edwards' motion to unseal. As you know, in our Response, the United States argued that this issue should be litigated in one of the suits filed by Mr. Edwards against Mr. Epstein. Mr. Edwards apparently b

r. Epstein has no interest in keeping the agreement confidential because he has not responded to Mr. Edwards' motion to unseal. As you know, in our Response, the United States argued that this issue should be litigated in one of the suits filed by Mr. Edwards against Mr. Epstein. Mr. Edwards apparently b

r. Epstein has no interest in keeping the agreement confidential because he has not responded to Mr. Edwards' motion to unseal. As you know, in our Response, the United States argued that this issue should be litigated in one of the suits filed by Mr. Edwards against Mr. Epstein. Mr. Edwards apparently b

r. Epstein has no interest in keeping the agreement confidential because he has not responded to Mr. Edwards' motion to unseal. As you know, in our Response, the United States argued that this issue should be litigated in one of the suits filed by Mr. Edwards against Mr. Epstein. Mr. Edwards apparently b

nunc pro tunc to disclose to Mr. Biran matters occurring before the grand jury, and enter a protective order. 18. In addition to the issue of the Response, during the OPR interview, must be able to explain the origins of the grand jury investigation, how it progressed, and how it continued even after

r. Epstein has no interest in keeping the agreement confidential because he has not responded to Mr. Edwards' motion to unseal. As you know, in our Response, the United States argued that this issue should be litigated in one of the suits filed by Mr. Edwards against Mr. Epstein. Mr. Edwards apparently b