EFTA00024032Set 8
2021-03-09134p50,001w
crimes relating to sexual trafficking of minors.
Expedite
Expedite Reason This request has been the subject of the request is of widespread and
exceptional media interest and the information sought ... your request so that it may be easily identified.
For questions on how to reasonably describe your request, please email us at
foloaauestions(atc.fbi.00v. You may also visit www.fbi ... Privacy Act (FOIPA) requests for information. RIDS provides
responsive documents to requesters seeking "reasonably described information." For a FOIPA search, the
subject's name, event, activity, or business is searched
https://www.justice.gov/epstein/files/DataSet%208/EFTA00024032.pdf
EFTA01100608Set 9
2011-04-0830p8,889w
summary judgment on all of Epstein's frivolous claims
for at least two separate reasons.
First, because Epstein has elected to hide behind the shield of his right against self ... event, these
allegations all fail for one straightforward reason: Edwards was simply not involved in any Ponzi
scheme, he has provided sworn testimony and an affidavit in support of that ... Undisputed Material Facts as Exhibit "N" at ¶8-10, ¶20, ¶22-23.
Indeed, no reasonable juror could find that Edwards was involved in the scheme, as Edwards joined
RRA well
https://www.justice.gov/epstein/files/DataSet%209/EFTA01100608.pdf
EFTA01263246Set 10
2016-03-1826p8,431w
gave no
reason, but as Maxwell made her motion on the basis of privacy concerns, and consented
to entry of some form of a protective order for the same reason ... S.D.N.Y. Aug. 21, 2012). But that does not strike this Court as a reason for the
Government to carry the firm's water—the moreso because Judge ruled some months ... Government's application.
B. The Martindell Standard Applies
Ordinarily, "Where there has been reasonable reliance by a party or deponent, a District
Court should not modify a protective order granted
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01263246.pdf
EFTA00024864Set 8
2007-08-074p836w
Charging O None Printed Nam`;,:
0 Other / /: (L-1/4—'
Reason Collected
Relinquished Custody Date and Accepted Custody Date and
Time Time
Signature: #,,,,...7 1. 44.4 0,4,„.• osbarsenfro signature ... t16044S)
Printed a 10: n dig... Printed Name
spo e 0 labota‘
Reason: -Th....ntrift,re--r- Reason: 7",,,ye. of
a
Relinquished (Custody Date and Accepted Custody Date ... 01is A— o _.0 e
Printed Name: Printed Name.
3:3O err. 31O17 i-,
Reason a Reason: STD IkA- Ge-
Relinquished Custody Date and Accepted Custody Date and
Time
https://www.justice.gov/epstein/files/DataSet%208/EFTA00024864.pdf
EFTA00075437Set 9
2020-08-0530p8,449w
prosecutions. To
make sure this would not happen, Congress expressly exempted records that could reasonably be
expected to interfere with law enforcement proceedings from public disclosure under FOIA ... also properly withheld
information where disclosure clearly would, and/or could reasonably be expected to, result in an
unwarranted invasion of privacy of Epstein's surviving family members, such as photographs ... supply "facts indicating that the agency has conducted a thorough search" and (2) give
"reasonably detailed explanations why any withheld documents fall within an exemption."
4
EFTA00075446
Case
https://www.justice.gov/epstein/files/DataSet%209/EFTA00075437.pdf
EFTA00314720Set 9
2011-12-0952p22,707w
Procedures. If all or any
portion of your subscription is not accepted for any reason, the unaccepted portion will be returned
to your account of origin without interest or deduction ... whole or in part, by the General Partner, in
its sole discretion, for any reason or no reason at any time prior to acceptance thereof. If all or any
portion ... Investor's Subscription Amount is rejected for any reason, the portion of the amount not
EFTA00314725
accepted will be returned to the Investor, without interest or deduction, via bank transfer
https://www.justice.gov/epstein/files/DataSet%209/EFTA00314720.pdf
EFTA01445565Set 10
78p20,128w
Access Funds" and
each an "Access Fund")
may be suitable and to use reasonable efforts to solicit such persons for
potential subscription of interests
in the Access Funds (the "Interests ... such
a market will ever develop. The
Investor further understands that for the foregoing reasons, the Investor
will be required to retain ownership
of the Interest and bear the economic ... contribution in respect of such Investor's Interest, unless this Agreement
is for any reason rejected or this
offering is for any reason canceled, and that default provisions with
respect
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01445565.pdf
EFTA00022091Set 8
2021-07-1234p11,082w
Page 2 of 34
related to the newly added sex trafficking charges. For the reasons that follow, the Court denies
Maxwell's motions to dismiss the SI superseding indictment ... expedite
discovery.
The Court provides a brief summary of its conclusions here and its reasoning on the
pages that follow:
• Maxwell moves to dismiss all counts based ... conspirator provision lacks any geographical or temporal
limitations. The Court disagrees for two independent reasons. First, under controlling Second
Circuit precedent, the NPA does not bind the U.S. Attorney
https://www.justice.gov/epstein/files/DataSet%208/EFTA00022091.pdf
EFTA00184197Set 9
2008-07-1527p7,073w
have a number of rights. Those rights arc:
(I) The right to be reasonably protected from the accused.
(2) The right to reasonable, accurate, and timely notice of any public ... present for other
portions of a proceeding.
(4) The right to be reasonably heard at any public proceeding in the district court
involving release, plea, or sentencing.
(5) The reasonable ... have a number of rights. Those rights are:
(I) The right to be reasonably protected from the accused.
(2) The right to reasonable, accurate, and timely notice of any public
https://www.justice.gov/epstein/files/DataSet%209/EFTA00184197.pdf
EFTA01189624Set 9
2013-11-0638p13,998w
very little daylight between it and the overwhelming
majority of American Jews. The reasons were several, but chief among
them was the fact that these were the same people ... insignificant as they did between 1939 and 1959. And American Jews had
objective reason to take pride in the heroic history of Zionism, both before
and after May 1948. That ... dropping out of so-
called liberal Judaism. Something similar, though not for the same reasons
or in the same way, is happening in Israel, and a more visibly religious
Israel
https://www.justice.gov/epstein/files/DataSet%209/EFTA01189624.pdf
EFTA00075004Set 9
2020-06-1020p5,220w
reasons for her objections are stated in her accompanying memorandum of law.
Ms. Maxwell, does not object to the potential unsealing of the Sealed Items contained ... Defendant
Ghislaine Maxwell, through her counsel objects to the unsealing of documents for the reasons
stated.
I. Overview
Docket Entries ("DEN") 143, 164, 172, 199, and 230 ("Sealed Material ... personal,
confidential, and subject to considerable abuse by the media. Countervailing interests include:
1. Reasonable reliance on a protective order by a party or non-party
https://www.justice.gov/epstein/files/DataSet%209/EFTA00075004.pdf
EFTA00292433Set 9
46p28,194w
Manager believe
that the expectations reflected in the forward-looking statements are reasonable, neither the General Partner nor the
Manager can guarantee the Fund's results and returns on investments ... about April 30, 2018. Such article contained material misstatements of fact, for which reason the General Partner issued a
corrective article on May 3. See 'Summary—Media Coverage for additional ... prospectus and does not purport in any manner to contain sufficient information a
reasonable purchaser may require to form an investment decision. This offering memorandum shall not be relied upon
https://www.justice.gov/epstein/files/DataSet%209/EFTA00292433.pdf