EFTA00015825

EFTA00020437

EFTA00020439

U.S. Department of Justice

U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Motto Building One Saint Andrew's Plaza New York. New York 10007 July 28, 2020 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: 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-captioned case, and to respond to the defendant's letter and 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, the parties

Case 9:08-cv-80736-KAM Document 50

Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 0372112011 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION FOR ORDER DIRECTING THE U.S. ATTORNEY'S OFFICE NOT TO WITHHOLD RELEVANT EVIDENCE COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for an order from this Court directing the U.S. Attorney's Office not to suppress material evidence relevant to this case. The Court should 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 the U.S. Attorney's Office about this case, counsel for Jane Doe #1 and Jane Doe #2 inquired about whether the Office would voluntarily provide to the victims information in its possession that was mater

Defense Claims DOJ Official Misrepresented Deferred Prosecution Agreement Modifications in Epstein Case

Defense Claims DOJ Official Misrepresented Deferred Prosecution Agreement Modifications in Epstein Case The passage outlines a dispute over a purported modification to Jeffrey Epstein's Deferred Prosecution Agreement (DPA) by U.S. Attorney Paul Acosta and SDFL prosecutor Michael Sloman. It suggests possible procedural misconduct or bad‑faith tactics by DOJ officials, which could be a concrete lead for further FOIA requests, interview of the attorneys involved, and review of the December 19, 2007 letter. While the actors are high‑profile (U.S. Attorney, federal prosecutors), the claim is not novel and lacks specific evidence of wrongdoing beyond contradictory statements, placing it in the strong‑lead range. Key insights: Sloman threatened to terminate the DPA unless Epstein complied with a 'unilateral modification' that defense says was never formally agreed to.; The defense asserts the December 19, 2007 letter from U.S. Attorney Acosta only proposed changes, which were rejected by defense counsel.; The SDFL allegedly refused to provide needed information for Epstein to meet the alleged new pleading and sentencing requirements.

From: '

From: ' To:' 1111 Cc: ' >, Subject: Re: RE: Epstein search warrant documents Date: Wed, 17 Jun 2020 19:13:54 +0000 Importance: Normal and I just spoke. We are going to down and take a look at all digital evidence and get this squared away. I'm going to work on getting a large enough hard drive to dump the evidence on to get it to SDNY. From: Sent: Wednesday, June 17, 2020 2:39 PM To: Cc: Subject: Fwd: RE: Epstein search warrant documents I know you already got this, just wanted to confer with you as to what is going on with all this. Feel like you, me, and need to chat and see what is what. I'm thinking that this started before the case took a turn yet is still moving in the same direction. In other words, do we really need to be doing this? Seems to me that I should be taking all my marching orders from and M. NY CART Coordinator Senior Forensic Examiner cell desk From: (USANYS)" Forwarded message Date: Jun 17, 2020 2:28 PM Subject: RE: Epstein search war