EFTA00029077Set 8
2017-06-3023p5,979w
Order 6
D. The Government's False Statements To Judge McMahon 6
E. Judge Netburn Separately Rejects An Identical Gambit By The Government 10
ARGUMENT 11
A. Pursuant ... Sealed Order ( I9-MC-00179 (SN)), 4/16/2019
EXHIBIT I: Sealed Letter to Judge Netburn, 4/9/2019
iv
EFTA00029081
Ghislaine Maxwell moves to suppress all evidence the government obtained from a grand ... Schiller's ninety-thousand-page
file, including Maxwell's two deposition transcripts.
E. Judge Netburn Separately Rejects An Identical Gambit By The
Government
Around the same time that Judge McMahon
https://www.justice.gov/epstein/files/DataSet%208/EFTA00029077.pdf
EFTA00021917Set 8
2020-07-221p265w
From: ' b"cl
PO
To: a
Subject: RE: draft letter to Netburn
Date: Wed, 22 Jul 2020 18:12:05 —0000
Attachments: 2020-07-22,_GMJetter_to_Judge_Nathan_re_Local_Rule_23.1.docx
Sorry guys ... Sent: Wednesday, July 22, 2020 1:57 PM
To: ;
Subject: RE: draft letter to Netburn
Looking at this now.
From:
Sent: Wednesday, July ... Subject: RE: draft letter to Netburn
No problem, totally understand.
From:
Sent: Wednesday, July 22, 2020 13:55
To:
Cc:
Subject: Re: draft letter to Netburn
Sorry guys
https://www.justice.gov/epstein/files/DataSet%208/EFTA00021917.pdf
EFTA00018749Set 8
2020-08-178p3,922w
Protective Order entered in Giuffre v. Maxwell was
entered by Magistrate Judge Netburn on November 29, 2018.5 That matter was settled and
dismissed on December 20, 2018. Jane ... protected under
the Protection Order from disclosures to non-parties) and that Magistrate Judge Netburn had
denied such a request from the government. Ms. Maxwell and her attorneys ... late March 2019 to Chief Judge McMahon and in April to
Magistrate Judge Netburn. During these ex parte proceedings, the government made numerous
unchallenged factual assertions. To Ms. Maxwell
https://www.justice.gov/epstein/files/DataSet%208/EFTA00018749.pdf
EFTA00086658Set 9
2017-06-3023p6,016w
Order 6
D. The Government's False Statements To Judge McMahon 6
E. Judge Netburn Separately Rejects An Identical Gambit By The Government 10
ARGUMENT 11
A. Pursuant ... Schiller's ninety-thousand-page
file, including Maxwell's two deposition transcripts.
E. Judge Netburn Separately Rejects An Identical Gambit By The
Government
Around the same time that Judge McMahon ... granted the government's ex parte request,
Magistrate Judge Netburn rejected an identical request from the government in a different civil
case, Jane Doe 43 v. Epstein, Case
https://www.justice.gov/epstein/files/DataSet%209/EFTA00086658.pdf
EFTA00031359Set 8
2020-07-221p210w
Attachments: 2020-07-22 JE letter to Netburn re order on unsealing.moe.docx
Here are some proposed edits. Thanks for drafting this.
From:
Sent: Wednesday, July ... Subject: RE: draft letter to Netburn
No problem, totally understand.
From:
Sent: Wednesday, July 22, 2020 13:55
To: >
Cc:
Subject: Re: draft letter to Netburn
Sorry guys ... Thanks either way and talk soon.
<2020-07-22, JE, letter to Netburn re order on unsealing.docx>
EFTA00031359
https://www.justice.gov/epstein/files/DataSet%208/EFTA00031359.pdf
EFTA00011452Set 8
2017-06-3023p6,031w
Order 6
D. The Government's False Statements To Judge McMahon 6
E. Judge Netburn Separately Rejects An Identical Gambit By The Government 10
ARGUMENT 11
A. Pursuant ... Schiller's ninety-thousand-page
file, including Maxwell's two deposition transcripts.
E. Judge Netburn Separately Rejects An Identical Gambit By The
Government
Around the same time that Judge McMahon ... case, Jane Doe 43 v. Epstein, Case No. 17-cv-616 (JGK) (SN). Judge Netburn recognized the
government's conduct for what it was: an attempt to deprive Maxwell
https://www.justice.gov/epstein/files/DataSet%208/EFTA00011452.pdf
EFTA00029816Set 8
2017-06-3023p5,973w
Order 6
D. The Government's False Statements To Judge McMahon 6
E. Judge Netburn Separately Rejects An Identical Gambit By The Government 10
ARGUMENT 11
A. Pursuant ... ninety-thousand-page)
e, Inc uding Maxwe 's two deposition transcripts
E. Judge Netburn Separately Rejects An Identical Gambit By The
Government
Around the same time that Judge McMahon granted ... case, Jane Doe 43 v. Epstein, Case No. 17-cv-616 (JGK) (SN). Judge Netburn recognized the
government's conduct for what it was: an attempt to deprive Maxwell
https://www.justice.gov/epstein/files/DataSet%208/EFTA00029816.pdf
EFTA00101468Set 9
2020-07-282p138w
filed under seal in this case.
Thank you,
Courtroom Deputy to the Hon. Sarah Netburn
United States District Court
Southern District of New York
Sent: Wednesda ... Jury u poena_ -mc-
To the Chambers of Judge Netburn:
Please see the attached letter in connection with the order referenced below, in the above-captioned case.
thank ... today in 19-mc-179.
Thank you,
EFTA00101468
Courtroom Deputy to the Hon. Sarah Netburn
United States District Court
Southern District of New York
EFTA00101469
https://www.justice.gov/epstein/files/DataSet%209/EFTA00101468.pdf
EFTA00030849Set 8
2021-01-213p208w
seal today in 19-mc-179.
Thank ou
Courtroom Deputy to the Hon. Sarah Netburn
United States District Court
Sent: Tuesda , Janua 19, 20217:08 PM
u ject ... will be filed under seal in this case.
Courtroom Deputy to the Hon. Sarah Netburn
United States District Court
Southern District of New York
Subject: RE: In Re: Grand Jury ... Subpoena_19-mc-00179
To the Chambers of Judge Netburn:
Please see the attached letter in connection with the order referenced below, in the above-captioned case.
Front
Sent: Wednesday
https://www.justice.gov/epstein/files/DataSet%208/EFTA00030849.pdf
EFTA00805057Set 9
2018-12-1314p5,713w
Tele hone:
December 13, 2018
VIA CM/ECF
Honorable Magistrate Judge Sarah Netburn
United States District Court
Thurgood Marshall Courthouse
40 Foley Square, Rm 430
New York, NY 10007
Re: Jane ... Case No.: 17-cv-00616 (JGK) — Letter Motion Seeking Pre-Motion Conference
Dear Judge Netburn,
We write today to request a pre-motion conference, pursuant to Local Civil Rule
https://www.justice.gov/epstein/files/DataSet%209/EFTA00805057.pdf
EFTA00080937Set 9
2019-02-053p925w
July 22, 2020
TO BE FILED UNDER SEAL
VIA EMAIL
The Honorable Sarah Netburn
United States District Court
Southern District of New York
United States Courthouse
New York, New York ... Application to Unseal Civil Discovery Materials, 19 Misc. 179 (SN)
Dear Judge Netburn:
The Government respectfully submits this letter in response to the Court's July 15, 2020
Order, directing
https://www.justice.gov/epstein/files/DataSet%209/EFTA00080937.pdf
EFTA00070830Set 9
2018-11-297p2,189w
DISCOVERY MATERIALS,
USAO Reference No. 2018R01618. SEALED ORDER
X
SARAH NETBURN, United States Magistrate Judge:
The United States Attorney for the Southern District of New York has moved, pursuant ... Case will
remain UNDER SEAL until further Court Order.
SO ORDERED.
vl v
SARAH NETBURN
United States Magistrate Judge
DATED: April 16, 2019
New York, New York
7
EFTA00070836
https://www.justice.gov/epstein/files/DataSet%209/EFTA00070830.pdf
EFTA00080936Set 9
2020-07-221p93w
Attachments:
To the Chambers of Judge Netburn:
Please see the attached letter in connection with the order referenced below, in the above-captioned case.
thank you,
From:
Sent: Wednesday, July ... filed under seal today in 19-mc-179.
Courtroom Deputy to the Hon. Sarah Netburn
United States District Court
Southern District of New York
EFTA00080936
https://www.justice.gov/epstein/files/DataSet%209/EFTA00080936.pdf
EFTA00019577Set 8
2019-04-092p196w
additional_authority,_17_Civ_0616_(SN)Jwith_exhibit).pdf
To the Chambers of Judge Netburn:
In connection with the Government's application relating to the above-captioned case, please ... Jane Doe 43 v. Epstein, et al., 17 Civ. 616 (JGK)(SN)
Mr.
Judge Netburn was wondering if you have a Word version of the Sealed Order that
https://www.justice.gov/epstein/files/DataSet%208/EFTA00019577.pdf
EFTA00011520Set 8
2019-02-286p2,862w
February 28, 2019
TO BE FILED UNDER SEAL
VIA EMAIL
The Honorable Sarah Netburn
United States District Court
Southern District of New York
United States Courthouse
New York, New York ... Application to Unseal Civil Discovery Materials, USAO No. 2018R01618
Dear Judge Netburn:
The Government writes respectfully in connection with its sealed application and proposed
order pursuant to the All Writs
https://www.justice.gov/epstein/files/DataSet%208/EFTA00011520.pdf