EFTA00210140Set 9
2015-07-0651p13,318w
various discovery related matters. In response to
Petitioners' first requests for production, the respondent Government asserted various privileges
in three privilege logs and submitted nearly 15,000 pages of documents ... Petitioners object to every privilege asserted. (DE 265).
Intervenor Jeffrey Epstein supports the Government's assertion that certain grand jury
materials should remain secret, and he moves to prevent disclosure ... those materials. (DE 263).
Petitioners filed a response. (DE 271).
Finally, the Government objects to the relevancy of several of Petitioners' requests for
production. (DE 260). Petitioners responded
https://www.justice.gov/epstein/files/DataSet%209/EFTA00210140.pdf
EFTA00028880Set 8
2016-01-1123p6,182w
Prosecution Agreement ("Motion").
As though it were wielding an invisible ink pen, the government adds language to its
Non-Prosecution Agreement ("NPA") with Jeffrey Epstein that does not exist ... conspirator of Epstein, the NPA,
on its face, applies here. Thus, the government's only argument, which it makes throughout its
opposition, is that the NPA means something other than ... immunize only the four individuals
specifically named in the co-conspirator immunity provision, the government flagrantly ignores
the express statement that immunity is "not limited to" those individuals. In arguing
https://www.justice.gov/epstein/files/DataSet%208/EFTA00028880.pdf
EFTA00078835Set 9
2011-04-0854p17,640w
statutory interpretation of the
language of the Crime Victims Rights Act (CVRA). Whether the government had a legal duty
under § 3771(a) is not resolved with reference to the position ... plea, and any sentencing, the right to confer with
the attorney for the government, the right to restitution, and the right to be
'Since no criminal case was pending ... rights in that she has received no
consultation with the attorney for the government regarding the possible
disposition of the charges, no notice of any public court proceedings, no
information
https://www.justice.gov/epstein/files/DataSet%209/EFTA00078835.pdf
EFTA00210569Set 9
2015-02-2325p8,788w
petitioners, Jane Doe No. 3 and Jane Doe No. 4. As the Government has previously
explained (see, e.g., D.E. 290 at 1-2), these CVRA proceedings are ancillary criminal
proceedings ... determining whether to expand the CVRA proceedings initiated by Jane Doe No. 1 and
Government Exhibit A
Case No. 08-80736-CIV-MARRA
EFTA00210569
Case ... stands the prosecutor. That state official has the power to employ the full
2
Government Exhibit A
Case No. 08-80736-CIV-MARRA
EFTA00210570
Case
https://www.justice.gov/epstein/files/DataSet%209/EFTA00210569.pdf
EFTA00077084Set 9
2020-07-287p3,567w
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter with respect to the protective order to be
entered in the above ... submission of
July 27, 2020 (the "Defendant Letter" or "Def. Ltr.") (Dkt. 29). The Government and defense
counsel have conferred regarding a protective order several times via telephone and email ... between
July 9, 2020, and today, including as recently as this morning. The Government and defense
counsel have come to an agreement on much of the proposed protective order. However
https://www.justice.gov/epstein/files/DataSet%209/EFTA00077084.pdf
EFTA00087774Set 9
2007-05-0121p5,654w
Excluded Under Rule 403 10
IV. In the Alternative, the Court Should Preclude the Government and Accuser-3 from
Representing that Accuser-3 Was a "Minor," or that ... Rules of Evidence. In the alternative, Ms. Maxwell
respectfully moves (1) to preclude the government and Accuser-3 from referring to Accuser-3 as
a "minor" or asserting that ... minor" at the time of the alleged sex acts, (2) to preclude
the government and Accuser-3 from representing that she was "sexually abused" by Jeffrey
Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00087774.pdf
EFTA01133557Set 9
2013-09-0841p16,854w
laying off workers. As part of the policy, known as Kurzarbeit in German, the
government partially reimburses workers for their lost wages. Work sharing is partly credited with
saving jobs ... Italy work on average 36 hours per week and like Germany the
Italian government has encouraged work-sharing for decades. Meanwhile, the maximum work week
for full-time employees ... plenty of areas for improvement. Executives panned the U.S. tax code, and
"competency of government" ranked very low on a list of factors that are important to business.
2. SWITZERLAND
https://www.justice.gov/epstein/files/DataSet%209/EFTA01133557.pdf
EFTA00074029Set 9
2019-07-0837p11,762w
DISTRICT COURT
DOC #:
SOUTHERN DISTRICT OF NEW YORK
DATE FILEaft
UNITED STATES OF AMERICA,
•
Government, 19 CR. 490 (RMB)
- against - DECISION & ORDER
• REMANDING DEFENDANT
JEFFREY EPSTEIN,
Defendant.
x
A. Background ... been given the opportunity to testify at the bail
hearing.
B. Counsels' Submissions
The Government's letter application, dated July 8, 2019, requests that the Court remand
Mr. Epstein ... Document 32 Filed 07/18/19 Page 3 of 33
11, Ex. I at 1. The Government also contends that "pin light of the strength of the Government's
evidence
https://www.justice.gov/epstein/files/DataSet%209/EFTA00074029.pdf
EFTA01128707Set 9
2013-07-0228p5,886w
EPSTEIN'S
INTERLOCUTORY APPEAL OF THE DISTRICT COURT'S DISCOVERY
ORDER DIRECTED TO THE GOVERNMENT. 10
A. The Supreme Court's Recent Decision in Mohawk Makes Clear that
Privilege Rulings ... following facts are taken from the District
Court's recent decision,
denying the Government's Motion to Dismiss, District Court Docket Entry (DE)
189, and related orders.
3
EFTA01128715
Case ... existence of the
agreement, either before or promptly after the fact — facts that the Government
apparently concedes. The U.S. Attorney's Office then kept the victims in the
dark about
https://www.justice.gov/epstein/files/DataSet%209/EFTA01128707.pdf
EFTA01074186Set 9
2011-04-1333p9,374w
that may
be temporarily called square-ocracy, or the transfer of power from
governments to masses of demonstrators in the streets." The main
square in Tunis, where protesters gathered ... dictator Zine el-
Abidine Ben Ali, is now named for Mohammad Bouazizi, the
desperate, government-harassed young street vendor whose self-
immolation helped topple the regime. Pro-government thugs loyal ... February on
protesters assembled in Tripoli's Green Square, threatening carnage
to come. The government of Bahrain shot protesters who were
gathering peacefully in its main urban landmark, Pearl Square
https://www.justice.gov/epstein/files/DataSet%209/EFTA01074186.pdf
EFTA00210894Set 9
2008-07-0714p4,366w
Jane Doe #1 on July 7, 2008 (D.E. I). The Court ordered
the Government to file a response by July 9, 2008, which was done. On July ... this
were a true civil action, then the addition of new parties would be governed by Fed.R.Civ.P. 15.
Brainard'. American Skandia Life Assurance Corp. 432 F.3d ... amendment of a pleading to add parties to an ongoing proceeding would be governed by
Fed.R.Civ.P. 15, and the futility of adding the § 3771 claims of Jane
https://www.justice.gov/epstein/files/DataSet%209/EFTA00210894.pdf
EFTA01183947Set 9
2008-07-0714p4,487w
Jane Doe #1 on July 7, 2008 (D.E. I). The Court ordered
the Government to file a response by July 9, 2008, which was done. On July ... this
were a true civil action, then the addition of new parties would be governed by Fed.R.Civ.P. 15.
Brainard v. American Skandia Life Assurance Corp. 432 F.3d ... amendment of a pleading to add parties to an ongoing proceeding would be governed by
Fed.R.Civ.P. 15, and the futility of adding the § 3771 claims of Jane
https://www.justice.gov/epstein/files/DataSet%209/EFTA01183947.pdf
EFTA00020298Set 8
2021-04-279p2,731w
filed a letter in opposition to the subpoena request. Additionally, the
Government submitted a letter requesting that it be given notice of all pending and future
subpoenas applications, an opportunity ... reserves judgment on Requests 9 through 11. The Court also
denies the Government's requests, though it will direct the Government to notify the Court of its
views ... target communications between "any" owner,
shareholder, partner or employee of BSF and government officials or co-counsel in civil
litigation, from 2015 to the date of the subpoena. While
https://www.justice.gov/epstein/files/DataSet%208/EFTA00020298.pdf
EFTA00604465Set 9
2017-07-0571p34,740w
delivery and compliance does not conflict with, or
constitute a default under, any instruments governing the Investor, or violate any law, regulation or
order, or any agreement to which ... General Partner, will furnish to
the Partnership true and correct copies of any instruments governing the Investor, including all
amendments to any such instruments and all authorizations. This Subscription Agreement ... Investor, if compelled to do so by
law or in connection with any government or self-regulatory organization request or investigation, or
if the General Partner and/or the Manager
https://www.justice.gov/epstein/files/DataSet%209/EFTA00604465.pdf
EFTA00102023Set 9
2020-07-3012p2,246w
GHISLAINE MAXWELL,
Defendant.
x
ALISON J. NATHAN, United States District Judge:
WHEREAS the Government intends to produce to GHISLAINE
MAXWELL, the defendant, certain documents and materials that
(i) affect ... privacy and confidentiality of individuals,
(ii) would impede, if prematurely disclosed, the Government's
ongoing investigation; (iii) would risk prejudicial pretrial
publicity if publicly disseminated, and (iv) is not authorized ... obligations (collectively,
the "Discovery"), which contain sensitive, confidential, or
personal identifying information;
WHEREAS, the Government seeks to protect sensitive,
confidential, or personal identifying information contained in
the materials it produces
https://www.justice.gov/epstein/files/DataSet%209/EFTA00102023.pdf
EFTA00985107Set 9
2014-02-2621p7,184w
financial stresses as well as the political pressures
from Congressional Republicans determined to slash government
spending. This year's $496 billion budget request, which conforms to
revised budget caps ... opposition to power — or futile, failing to tip the
balance against the government of President Bashar al-Assad. Using force,
it is argued, would also jeopardize other strategic objectives, like ... United
Nations envoy Lakhdar Brahimi, the peace talks in Geneva between the
Syrian government and the opposition coalition have become a waste of
time. The opposition forces have been weakened
https://www.justice.gov/epstein/files/DataSet%209/EFTA00985107.pdf