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EFTA01657752Set 10

2015-07-0651p13,321w

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%2010/EFTA01657752.pdf

EFTA00267621Set 9

Ryan Commissioner Crime Command SPECIFIC TARGETING OF AN INDIVIDUAL OVER A 27 YEAR PERIOD GOVERNMENT AND POLICE TARGETING BY THE USE OF TECHNOLOGY - 1993 - 2021 ILLEGAL SURVEILLANCE PRIVACY OF VICTIMS ... Multiple Intellectual Property Theft occurring following Hand written business concepts and businesses, including Government policies and council developments, not shared with a third party, including family members, not installed ... computer, hand written in Privacy of victims own home 1993 - 2021. Government and Police Illegal Surveillance, and including shared surveillance with organised crime Syndicate Business concepts and developments

https://www.justice.gov/epstein/files/DataSet%209/EFTA00267621.pdf

EFTA00267652Set 9

Commissioner Specialist Protective Command SPECIFIC TARGETING OF AN INDIVIDUAL OVER A 27 YEAR PERIOD GOVERNMENT AND POLICE TARGETING BY THE USE OF TECHNOLOGY - 1993 - 2021 ILLEGAL SURVEILLANCE PRIVACY OF VICTIMS ... Multiple Intellectual Property Theft occurring following Hand written business concepts and businesses, including Government policies and council developments, not shared with a third party, including family members, not installed ... computer, hand written in Privacy of victims own home 1993 - 2021. Government and Police Illegal Surveillance, and including shared surveillance with organised crime Syndicate Business concepts and developments

https://www.justice.gov/epstein/files/DataSet%209/EFTA00267652.pdf

EFTA01079938Set 9

2013-08-1618p5,478w

previously reserved ruling on this motion. DE 99 at 11. In light of the Governments' recent decision to assert that thousands of pages of documents are privileged — and to produce ... impossible to understand what kinds of documents have been produced, or even whether the Government has responded to each request at all — the Court should now grant the motion ... largely or entirely avoid the need for a document-by-document review of the Government's privilege assertions and the victims' responses to them. BACKGROUND As the Court is aware

https://www.justice.gov/epstein/files/DataSet%209/EFTA01079938.pdf

EFTA00018997Set 8

2014-10-2420p4,647w

FOURTH AMENDMENT, MARTINDELL, AND THE FIFTH AMENDMENT TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S SUBPOENA TO BOLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca ... TABLE OF AUTHORITIES iii TABLE OF EXHIBITS Factual Background 1 Argument 1 I. The Government's violation of the Fourth Amendment requires suppression 1 A. Maxwell has standing ... There is no good faith. 5 C. The government's inevitable discovery doctrine fails 5 II. The Government's violation ofManindell requires suppression. 7 III. The Government's violation

https://www.justice.gov/epstein/files/DataSet%208/EFTA00018997.pdf

EFTA00084567Set 9

2020-07-2819p5,808w

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/EFTA00084567.pdf

EFTA00591461Set 9

2017-06-0233p10,820w

Document 401-2 Entered on FLED Docket 06/02,017 Page 1 of 33 GOVERNMENT EXHIBIT EFTA00591461 Case 9:08-cv-80736-KAM Document 401-2 Entered on FLSD Docket 06/02/2017 ... MARRA JANE DOE I AND JANE DOE 2, Petitioners, vs. UNITED STATES, Respondent. GOVERNMENT'S RESPONSE AND OPPOSITION TO PETITIONERS' MOTION FOR PARTIAL SUMMARY JUDGMENT AND CROSS-MOTION FOR SUMMARY ... Judgment and Cross- Motion for Summary Judgment, and states: I. INTRODUCTION Petitioners contend the Government violated their rights under the Crime Victims' Rights Act ("CVRA"), 18 U.S.C

https://www.justice.gov/epstein/files/DataSet%209/EFTA00591461.pdf

EFTA00205867Set 9

2011-09-2613p5,446w

JANE DOE #1 AND JANE DOE #2'S FIRST REQUEST FOR PRODUCTION TO THE GOVERNMENT REGARDING INFORMATION RELEVANT TO THEIR PENDING ACTION CONCERN THE CRIME VICTIMS RIGHTS ACT COME ... victims"), by and through undersigned counsel, and request the defendant United States (hereinafter "the Government") to produce the original or best copy of the items listed herein below for inspection ... Court's Order (DE #99) directing discovery in this case. BACKGROUND As the Government will recall, the victims have asked the Government to stipulate to undisputed facts in this case

https://www.justice.gov/epstein/files/DataSet%209/EFTA00205867.pdf

EFTA01081219Set 9

2013-10-289p2,395w

Withhold Relevant Evidence (DE 50, renewed in DE 226), in light of the Government's response (DE 230). The Government's response confirms each of the victims' arguments in support ... their motion, specifically (1) that the Government's privilege log is grossly inadequate; (2) the CVRA's requirement that the Government exercise its "best efforts" to protect crime victims' rights ... provide the materials that it has received in camera to the victims. I. THE GOVERNMENT'S PRIVILEGE LOG IS GROSSLY INADEQUATE. In their motion, the victims explained that the Government

https://www.justice.gov/epstein/files/DataSet%209/EFTA01081219.pdf

EFTA01125545Set 9

2009-03-1515p7,691w

E.D.N.Y. 2008). The court cannot "compromise[e] its ability to be impartial to the government and defendant, the only true parties." Id. at 428. "As for actual clashes between victim ... government over the best way to convict, punish and seek restitution from a criminal wrongdoer, how can the court presiding over the prosecution of the defendant referee any spat between ... government and victim about how best to make the accused pay for his, at that point, only charged criminal conduct?" Id. at 429. A victim has no right to appeal

https://www.justice.gov/epstein/files/DataSet%209/EFTA01125545.pdf

EFTA02010032Set 10

2012-09-0937p9,837w

have largely centered on defending computer networks against attacks by hackers, criminals and foreign governments, mainly China. Increasingly, however, the focus is on developing offensive capabilities, on figuring ... clearly needed are new international understandings about what constitutes cyber aggression and how governments should respond. Meanwhile, the United States must do what it can to protect its own networks ... young men with hands bound, have been found dumped by the road in government-held areas. On September 5th, 45 such bodies were said to have been retrieved

https://www.justice.gov/epstein/files/DataSet%2010/EFTA02010032.pdf

EFTA00212458Set 9

2011-03-2115p4,096w

enter an order, as it would in other criminal or civil cases, requiring the Government to make appropriate production of such evidence to the victims. BACKGROUND In discussions with ... victims. Second, just as criminal defendants are entitled to receive favorable information in the Government's possession under due process rights, see, e.g., Brady. Maryland, 373 U.S. 83 (1963), victims ... standard discovery order that this Court routinely enters in criminal cases. DISCUSSION I. THE GOVERNMENT VIOLATES ITS "BEST EFFORTS" OBLIGATIONS IF IT WITHOLDS EVIDENCE FAVORABLE TO THE VICTIMS

https://www.justice.gov/epstein/files/DataSet%209/EFTA00212458.pdf

EFTA01206503Set 9

2014-11-1419p5,722w

Petitioners, vs. UNITED STATES, Respondent. RESPONDENT'S RESPONSE TO PETITIONERS' REASSERTION OF OBJECTIONS TO GOVERNMENT'S ASSERTIONS OF PRIVILEGES Respondent, by and through its undersigned counsel, files its Response ... Petitioners' Reassertion of Objections to Government's Assertions of Privileges (D.E. 265), and states: I. THE GOVERNMENT'S PRIVILEGE LOGS ADEQUATELY INFORM PETITIONERS AND THE COURT OF THE PRIVILEGE BEING ... ASSERTED, AS WELL AS THE NATURE OF THE DOCUMENT The government has provided adequate privilege logs which inform petitioners and the Court of the privilege being asserted, as well

https://www.justice.gov/epstein/files/DataSet%209/EFTA01206503.pdf

EFTA01141381Set 9

2014-02-0231p14,896w

times of national turmoil that brought him into direct confrontation with the U.S. government, corporate interests, and people who did not share his beliefs," William Ruhlmann wrote in a biography ... back educational institutions. If Social Security garnishing becomes widespread, you can bet the government may find itself having to negotiate a solution -- perhaps taking on the student loan defaults ... incurring more government debt) in order to protect seniors. In addition, as I have found during my reporting, many people are too proud to declare bankruptcy even in dire circumstances

https://www.justice.gov/epstein/files/DataSet%209/EFTA01141381.pdf

EFTA00023378Set 8

2021-11-107p1,765w

regarding these logistical considerations. Because this letter contains identifying information relating to victims, the Government respectfully requests that the Court accept the Government's proposed redactions to this letter. Government ... With respect to nomenclature for witnesses whose identities should be protected at trial, the Government respectfully submits the following chart, which provides the true names of witnesses and the proposed ... Document 432 Filed 11/10/21 Page 2 of S Page 2 The Government submits that this nomenclature can be used when trial begins on November 29, 2021, but that the parties

https://www.justice.gov/epstein/files/DataSet%208/EFTA00023378.pdf

EFTA02019942Set 10

2012-02-2739p9,116w

agreement with the Palestinian Authority's Mahmoud Abbas to form a "temporary" technocrats' Unity Government, with Abu Mazen himself as prime minister.They also agreed to postpone general elections without fixing ... agreed, at least implicitly, to make a major concession: to dismantle Hamas' s own government in Gaza, which has ruled the Strip for the last five years, and to allow ... prime minister was described as "unconstitutional." Ismail Haniyeh, the prime minister of the Hamas government in Gaza, embarked on a tour of several Arab countries avoiding any hint of support

https://www.justice.gov/epstein/files/DataSet%2010/EFTA02019942.pdf

EFTA01098037Set 9

2011-10-1421p6,534w

have the letters or emails written by the defense attorneys to the government. The plaintiffs only have the letters from the government to the defense attorneys, pursuant to orders issued ... Magistrate Judge Johnson that addressed the plaintiffs' request "for documents the federal government gave to Epstein in the course of its plea discussions with him" and "documents . .. given ... government to Epstein ...." [DE 462 at 7, 10] (emphasis in original); see also [Order, DE 513 at 2] (ruling on "documents the government itself gave Epstein"). This pleading replies

https://www.justice.gov/epstein/files/DataSet%209/EFTA01098037.pdf

EFTA00263717Set 9

2015-04-0717p5,974w

alleged victims seeking to reopen Epstein's non-prosecution plea agreement with the federal government; the judge ordered that allegation to be struck from the record.11 Judge Marra made ... Plus Health Care Strate;i (PDF 4681Cewas releasedty the South Aus tan ,k Government in August 2117 = i e trategAndeTins SA. Health's approach tqhealth carein South Australia, in particular ... approach to primary and community care. The Strategy aims to: • facilitate the Government's agenda to provide a fully integrated and accessible health care system and increase health promotion, illness

https://www.justice.gov/epstein/files/DataSet%209/EFTA00263717.pdf

EFTA01142189Set 9

2013-09-0313p3,647w

Compel Production of Documents That Are Not Privileged (D.E. 225), and state: I. THE GOVERNMENT HAS ASSERTED VALID PRIVILEGES TO DISCLOSURE OF THE REQUESTED DOCUMENTS The government has provided adequate ... argue that the privilege log is inadequate, and that lais a result of the Government's failures, it is impossible to even begin to determine which of the Government ... rejected because petitioners can be presumed to know what these documents are. The government invoked the work product doctrine for a number of documents, including a file folder entitled, "Mann

https://www.justice.gov/epstein/files/DataSet%209/EFTA01142189.pdf

EFTA01939256Set 10

2014-01-2233p8,187w

police, it reports the murder of some 11,000 men detained by the Syrian government between 2011 and last August. Many of the bodies in the photographs show signs ... community tries to organize itself." The jurists, former war-crimes prosecutors commissioned by the government of Qatar, concluded that the "evidence would support findings of crimes against humanity against ... stop them. On the contrary: It may serve to prop up the Assad government by treating it as a legitimate party to negotiations about Syria's future. Mr. Kerry insists

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01939256.pdf

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