Epstein Files Search

EFTA00605165Dataset 9

2017-10-042p696w

…and only sonic of the documents she produced, but Plaintiff would not, however, consent to the use of all of the Jane Doe Evidence. On October 3, 2017, we submitted a letter motion to Judge Sweet seeking permission to file under seal a motion to modify the Protective Order entered in the Giuffre matter before him. On October 4, 2017, Judge Sweet granted the letter motion to file under seal. As a result, we will be filing tomorrow the motion…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00605165.pdf

EFTA00787645Dataset 9

2017-10-2611p2,606w

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, —against— 15 Civ. 7433 (RWS) GHISLAINE MAXWELL, Defendant. REPLY MEMORANDUM OF LAW IN SUPPORT OF INTERVENORS' MOTIONS FOR LEAVE TO INTERVENE AND TO MODIFY THE PROTECTIVE ORDER STEPTOE & JOHNSON LLP 1114 Avenue of the Americas New York, New York 10036 October 26, 2017 Doc. # DC-10535528 v.5 EFTA00787645 TABLE OF CONTENTS SUMMARY OF THE REPLY ARGUMENT A. The Jane Doe Evidence Is Relevant to the Motion to Dismiss the…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00787645.pdf

EFTA01263246Dataset 10

2016-03-1826p8,431w

To Be Filed Under Seal UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK C IN RE GRAND JURY SUBPOENA 19 Misc. 149 (CM) x SEALED MEMORANDUM DECISION AND ORDER GRANTING THE GOVERNMENT'S APPLICATION TO MODIFY THE PROTECTIVE ORDER McMahon, C.J.: The Government has filed an application for modification of a March 18, 2016 pretrial protective order, entered by the late Hon. in a civil defamation action, v. Maxwell, No. 15-cv-7433 (S.D.N.Y.) ("the…

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01263246.pdf

EFTA00086685Dataset 9

2016-03-1827p8,445w

EXHIBIT G EFTA00086685 To Be Filed Under Seal UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x C IN RE GRAND JURY SUBPOENA 19 Misc. 149 (CM) x SEALED MEMORANDUM DECISION AND ORDER GRANTING THE GOVERNMENT'S APPLICATION TO MODIFY THE PROTECTIVE ORDER McMahon, C.J.: The Government has filed an application for modification of a March 18, 2016 pretrial protective order, entered by the late Hon. Robert W. Sweet in a civil defamation action, Giuffre v. Maxwell, No…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00086685.pdf

EFTA00805389Dataset 9

2017-10-0518p5,208w

…from the Matter and some of the documents she produced in that matter (the "Agreed Evidence"). Intervenors seek through the instant motion to obtain an order from the Court modifying the Protective Order to permit Intervenors to use all of the Jane Doe Evidence to support the Motion to Dismiss. To modify the Protective Order, the Court must first find that Intervenors have "a claim or defense that shares with the main action a common question of law or fact"…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00805389.pdf

EFTA00018749Dataset 8

2020-08-178p3,922w

…Corp., 594 F.2d 291, 293 (2d Cir. 1979). EFTA00018753 The Honorable Alison J. Nathan August 17, 2020 Page 6 There are at least three compelling reasons to modify the Protective Order. First, Judge Preska might well decline to unseal Ms. Maxwell's depositions if she knew how the government obtained it despite the Protective Order. We do not know what impact the government's possession of the BSF file may have on the carefully crafted unsealing process. Judge Preska…

https://www.justice.gov/epstein/files/DataSet%208/EFTA00018749.pdf

EFTA00017803Dataset 8

2020-08-212p329w

Subject: FW: New document: v. Maxwell (Doc# -, 2d Cir.

From: "To: ' ,SYS)" < (USANYS)"

…Cir. Date: Fri, 21 Aug 2020 03:36:28 +0000 Attachments: 2020-08-20J-000LBRIEF,_on_behalf of Appellant_Ghislaine_Maxwell,FILED..pdf Inline-Images: image001.jpg FYI. In this brief, Maxwell's attorneys state that if Judge Nathan denies their motion to modify the protective order, they will appeal to the Second Circuit and seek consolidation of that appeal with the appeal from Judge Preska's order. From: Sigrid McCawley Sent: Thursday, August 20, 2020 8:27 PM To…

https://www.justice.gov/epstein/files/DataSet%208/EFTA00017803.pdf

EFTA00087357Dataset 9

2020-09-023p249w

…case, hereby appeals to the United States Court of Appeals for the Second Circuit from the district court's September 2, 2020, Memorandum Opinion and Order denying her motion to modify the protective order. Pichler v. UNITE, 585 F.3d 741, 746 n.6 (3d Cir. 2009) ("We have jurisdiction under the collateral order doctrine to review the denial of the motion to modify the Protective Order and the denial of the motion to reconsider."); Minpeco S.A. v. Conticommodity…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00087357.pdf

EFTA00074890Dataset 9

2020-06-1213p2,918w

…modify the protective order entered in v. Maxwell, No. 15 Civ. 7433 (S.D.N.Y.), to permit him access to "all filings and discovery materials, including third- party discovery" from that case. (See Dershowitz Letter Requesting Pre-Motion Conference on Motion to Modify the Protective Order ("Dershowitz June 12 Letter"), dated June 12, 2020 [dkt. no. 133 in 19 Civ. 3377].) Mr. Dershowitz originally sought the Court's leave to fully brief a motion to modify the protective order…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00074890.pdf

EFTA00595640Dataset 9

2015-09-217p1,505w

…88 Filed 04/08/16 Page 2 of 7 INTRODUCTION Defendant Ghislaine Maxwell, through her attorneys, objects to the Motion for Admission Pro Hac Vice filed by Bradley Edwards (Doc#86). In the alternative Ms. Maxwell requests that the Court modify the Protective Order, (Doc. # 62) to restrict Mr. Edwards's access to information designated "confidential" for the following reasons. ARGUMENT This case has been pending since September 21, 2015. Plaintiff is represented in this case by 4 attorneys from…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00595640.pdf

EFTA00066348Dataset 9

2019-04-092p253w

…133, 139) are DENIED. The Court sets out its reasoning in an opinion concurrently filed under temporary seal to allow Maxwell and the Government the opportunity to propose redactions. The parties may file under seal any proposed redactions to the opinion within three days. The Court further ORDERS that the April 9, 2019 memorandum decision and order on the Government's application to modify the protective order in v. Maxwell, No. 15-cv- 7433, as well as the transcripts of…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00066348.pdf

EFTA00077311Dataset 9

2020-02-1114p4,323w

…586 to 586-3, 620 to 621, and 872]; and (b) all unified discovery deposition transcripts and exhibits thereto. The USVI seeks to modify the Protective Order [ECF No. 62] solely to be granted confidential access to these materials, and, if granted access, agrees to be bound by the Protective Order. The USVI seeks confidential access to these sealed documents and unfiled discovery materials because they are very likely relevant to its pending Virgin Islands Criminally Influenced and Corrupt Organizations…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00077311.pdf

EFTA00087228Dataset 9

2019-04-092p251w

…are DENIED. The Court sets out its reasoning in an opinion concurrently filed under temporary seal to allow Maxwell and the Government the opportunity to propose redactions. The parties may file under seal any proposed redactions to the opinion within three days. The Court further ORDERS that the April 9, 2019 memorandum decision and order on the Government's application to modify the protective order in v. Maxwell, No. as well as the transcripts of the March 26, 2019 and…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00087228.pdf

EFTA00595633Dataset 9

2015-09-217p1,505w

…88 Filed 04/08/16 Page 2 of 7 INTRODUCTION Defendant Ghislaine Maxwell, through her attorneys, objects to the Motion for Admission Pro Hac Vice filed by Bradley Edwards (Doc#86). In the alternative Ms. Maxwell requests that the Court modify the Protective Order, (Doc. # 62) to restrict Mr. Edwards's access to information designated "confidential" for the following reasons. ARGUMENT This case has been pending since September 21, 2015. Plaintiff is represented in this case by 4 attorneys from…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00595633.pdf

EFTA01111913Dataset 9

2015-09-217p1,509w

…88 Filed 04/08/16 Page 2 of 7 INTRODUCTION Defendant Ghislaine Maxwell, through her attorneys, objects to the Motion for Admission Pro Hac Vice filed by Bradley Edwards (Doc#86). In the alternative Ms. Maxwell requests that the Court modify the Protective Order, (Doc. # 62) to restrict Mr. Edwards's access to information designated "confidential" for the following reasons. ARGUMENT This case has been pending since September 21, 2015. Plaintiff is represented in this case by 4 attorneys from…

https://www.justice.gov/epstein/files/DataSet%209/EFTA01111913.pdf

EFTA00073260Dataset 9

2020-02-1114p4,343w

…586 to 586-3, 620 to 621, and 872]; and (b) all unfiled discovery deposition transcripts and exhibits thereto. The USVI seeks to modify the Protective Order [ECF No. 62] solely to be granted confidential access to these materials, and, if granted access, agrees to be bound by the Protective Order. The USVI seeks confidential access to these sealed documents and unfiled discovery materials because they are very likely relevant to its pending Virgin Islands Criminally Influenced and Corrupt Organizations…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00073260.pdf

EFTA01186706Dataset 9

2015-09-217p1,510w

…88 Filed 04/08/16 Page 2 of 7 INTRODUCTION Defendant Ghislaine Maxwell, through her attorneys, objects to the Motion for Admission Pro Hac Vice filed by Bradley Edwards (Doc#86). In the alternative Ms. Maxwell requests that the Court modify the Protective Order, (Doc. # 62) to restrict Mr. Edwards's access to information designated "confidential" for the following reasons. ARGUMENT This case has been pending since September 21, 2015. Plaintiff is represented in this case by 4 attorneys from…

https://www.justice.gov/epstein/files/DataSet%209/EFTA01186706.pdf

EFTA01182940Dataset 9

2015-09-217p1,514w

…88 Filed 04/08/16 Page 2 of 7 INTRODUCTION Defendant Ghislaine Maxwell, through her attorneys, objects to the Motion for Admission Pro Hac Vice filed by Bradley Edwards (Doc#86). In the alternative Ms. Maxwell requests that the Court modify the Protective Order, (Doc. # 62) to restrict Mr. Edwards's access to information designated "confidential" for the following reasons. ARGUMENT This case has been pending since September 21, 2015. Plaintiff is represented in this case by 4 attorneys from…

https://www.justice.gov/epstein/files/DataSet%209/EFTA01182940.pdf

EFTA00029951Dataset 8

2018-11-294p2,283w

…until further Court Order. *4 The subject matter of the Government's investigation is obviously serious. But to pierce the Protective Order, the SO ORDERED. Government must demonstrate not that this investigation is an extraordinary circumstance, but that the reasonfor seeking the documents is so extraordinary or compelling that there is All Citations a need to modify the Protective Order. The Government has not met that standard. Slip Copy, 2021 WL 1164272 Footnotes 1 The Protective Order covers "information whose…

https://www.justice.gov/epstein/files/DataSet%208/EFTA00029951.pdf

EFTA00087230Dataset 9

2016-02-2921p6,032w

…absent any such misrepresentation. The Court finds that Maxwell has not made a substantial preliminary showing on either prong. Maxwell's argument here centers on the Government's statements to Judge McMahon during the second proceeding on April 9, 2019, concerning its application to modify the protective order. At that proceeding, Judge McMahon explained that she wanted to make sure the Government's request did not present a similar situation to that in Chemical Bank v. Affiliated FM Ins. Co.…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00087230.pdf