EFTA00026750Set 8
2020-07-2819p5,810w
United States v. Gleislaine 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%208/EFTA00026750.pdf
EFTA00098414Set 9
2019-02-2133p11,272w
Motion for Finding Waiver of Work Product and Similar Protections by
Government and for Production of Documents (DE 414). The Motions are fully briefed and ripe
for review. The Court ... mansion
in Palm Beach, Florida, and elsewhere in the United States and overseas. (Government Resp. to
Petitioner's Statement of Undisputed Material Facts (hereinafter, "DE 407" at 9 1.) Because ... Jane Doe 1 relied on those representations and believed that the
Government would protect those rights and keep her informed about the progress of her case
https://www.justice.gov/epstein/files/DataSet%209/EFTA00098414.pdf
EFTA00020261Set 8
2021-07-1234p11,082w
Jeffrey Epstein's sexual abuse of minor victims from around
1994 to 1997. The Government filed a first (S1) superseding indictment shortly thereafter,
which contained only small, ministerial corrections ... offenses.
• Maxwell moves to dismiss all counts as untimely. The Court concludes that the
Government brought the charges within the statute of limitations and did not unfairly
delay in bringing ... counts because they are too vague, or in the
alternative to require the Government to describe the charges in greater detail. The
Court concludes that the charges are specific enough
https://www.justice.gov/epstein/files/DataSet%208/EFTA00020261.pdf
EFTA00103273Set 9
2021-07-1234p11,087w
Jeffrey Epstein's sexual abuse of minor victims from around
1994 to 1997. The Government filed a first (S1) superseding indictment shortly thereafter,
which contained only small, ministerial corrections ... offenses.
• Maxwell moves to dismiss all counts as untimely. The Court concludes that the
Government brought the charges within the statute of limitations and did not unfairly
delay in bringing ... counts because they are too vague, or in the
alternative to require the Government to describe the charges in greater detail. The
Court concludes that the charges are specific enough
https://www.justice.gov/epstein/files/DataSet%209/EFTA00103273.pdf
EFTA01891476Set 10
2012-08-3146p10,717w
divided not only
over security strategy, but the conservative base is also
fractured over government spending — including the
defense budget. Neoconservatives who opposed even
the modest defense cuts suggested ... Grover G. Norquist. At the same time, some
Republicans who have long said that government
spending doesn't generally create jobs have promised
— hypocritically — to oppose defense cuts that might ... explicit programs to
create jobs, targeted at labor-intensive sectors that
enjoy comparative advantage. Governments, working
with private companies, need to improve access to
finance in those sectors, build
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01891476.pdf
EFTA01187946Set 9
2013-01-1327p16,501w
debt negotiations, gun violence that has the NRA advocating
arming teacher and a potential government shutdown so that Republican conservatives can say that the
President Obama is a weak leader ... breaks/incentives, that will stimulate the country's economy is naive.... This is the government's job....
Hopefully our Politicians will allow the government to do its job And protecting ... Bureau's official figures fail to paint a
complete picture, though. The formula the government uses to calculate the poverty rate was
designed in the 1960s, and does not account
https://www.justice.gov/epstein/files/DataSet%209/EFTA01187946.pdf
EFTA00089393Set 9
2019-07-1228p13,903w
United States v. Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear Judge Berman:
The Government respectfully submits this letter in response to the defendant's Motion for
Pretrial Release (the "Release ... pledging as the
principal security a property that has already been identified by the Government as subject to
forfeiture upon the defendant's conviction, and which therefore ... many years. And
following the defendant's prior conviction, as described previously by the Government, the
defendant continued to maintain at least hundreds and possibly thousands of nude photos
https://www.justice.gov/epstein/files/DataSet%209/EFTA00089393.pdf
EFTA00076331Set 9
2019-07-1228p13,950w
United States v. Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear Judge Berman:
The Government respectfully submits this letter in response to the defendant's Motion for
Pretrial Release (the "Release ... pledging as the
principal security a property that has already been identified by the Government as subject to
forfeiture upon the defendant's conviction, and which therefore ... many years. And
following the defendant's prior conviction, as described previously by the Government, the
defendant continued to maintain at least hundreds and possibly thousands of nude photos
https://www.justice.gov/epstein/files/DataSet%209/EFTA00076331.pdf
EFTA00039383Set 9
2019-07-0833p10,702w
COURT
DOC #:
SOUTHERN DISTRICT OF NEW YORK
—x DATE FILED:
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/EFTA00039383.pdf
EFTA00023059Set 8
2006-07-1914p6,635w
Through repeated communications with the USAO and senior Department officials,
defense counsel fought the government's interpretation of the NPA's terms. They also sought and
obtained review ... federal court in the Southern
District of Florida an emergency petition alleging that the government violated the Crime Victims'
Rights Act (CVRA), 18 U.S.C. § 3771, when it resolved the federal ... victims, and seeking enforcement of her CVRA rights.2 In responding to
the petition, the government, represented by the USAO, revealed the existence of the NPA, but did
not produce
https://www.justice.gov/epstein/files/DataSet%208/EFTA00023059.pdf
EFTA00058455Set 9
2019-07-1214p7,859w
United States v. Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear Judge Berman:
The Government respectfully submits this letter in response to the defendant's Motion for
Pretrial Release (the "Release ... pledging as the
principal security a property that has already been identified by the Government as subject to
forfeiture upon the defendant's conviction, and which therefore ... many years. And
following the defendant's prior conviction, as described previously by the Government, the
defendant continued to maintain at least hundreds and possibly thousands of nude photos
https://www.justice.gov/epstein/files/DataSet%209/EFTA00058455.pdf
EFTA01785152Set 10
2013-05-1321p11,028w
Kerry announced th=t they would host an international conference where Syrian government
officials and rebels will be given a chance to name an i=terim government
<http:=/www.reuters.com/article/2013/05/07/us-syria-crisis-conference-idUSBRE9461=S20130507 ... nference should be carried out. Both sides may miraculously agree on an in=erim
government.
But it is more likely that the =nited States has lost control of the rebels ... jihadists converging on Iraq to fight=the Americans and the Shiites — the Maliki government, with oil money, and
anchored in the power of the (Shiit=) Dawa party, is throwing
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01785152.pdf
EFTA00652576Set 9
2013-03-1026p14,266w
constitution, participatory democratic
councils, the nationalization of several key industries, increased government funding of health care
and education, and significant reductions in poverty, according to government figures. Under Chavez,
Venezuelans ... Chavez led the MBR-200 in an unsuccessful coup against the Democratic Action government
of President Carlos Andres Perez in 1992, for which he was imprisoned. Released from prison after ... constitution which increased rights for marginalized groups and
altered the structure of Venezuelan government, and was re-elected in 2000. During his second
presidential term, he introduced a system
https://www.justice.gov/epstein/files/DataSet%209/EFTA00652576.pdf
EFTA00795150Set 9
2013-07-0520p5,123w
F.3d 936, 940 (11th Cir. 1999) ("[W]e
determine whether this lawsuit survives the government's factual attack [on subject matter
jurisdiction] by looking to matters outside the pleadings ... standing. Nonetheless, the
circumstances which demonstrate Petitioners' lack of a concrete injury traceable to government
conduct are explored infra in Section II of this memorandum, which addresses how Petitioners'
claims ... States v. Harvey, 869 F.2d 1439, 1443 (11th Cir. 1989) ("Due
process requires the government to adhere to the terms of any plea bargain or immunity
agreement it makes."). Indeed
https://www.justice.gov/epstein/files/DataSet%209/EFTA00795150.pdf
EFTA01115824Set 9
2014-02-26181p90,937w
Investors. 120
(3) NNA Used As Internal Performance Measure 122
D. Financial Standards Governing NNA Reporting 123
(1) Standards for Disclosing Total NNA 123
(2) Internal Bank Process for Recognizing ... through hidden foreign
accounts. It examines, in particular, ongoing roadblocks erected by the Swiss Government to
block bank disclosure of the names of former U.S. customers with undeclared Swiss accounts ... from 16 additional
parties, conducted 23 interviews of personnel at the bank, the U.S. Government, and other
sources, as well as U.S. taxpayers who had evaded U.S. taxes using hidden
https://www.justice.gov/epstein/files/DataSet%209/EFTA01115824.pdf