To: Nathan NYSD Chambers
Summary
From: To: Nathan NYSD Chambers Cc: Subject: US v. Maxwell, 20 Cr. 330 (AJN) - Government Request for Redactions Date: Fri, 23 Apr 2021 15:41:04 +0000 Attachments: 2021-04-23_Govtletter_re_proposed_redactions_to_GM_17(c)_filings.pdf; Ex._B_2021.04.05_BSF_Reply_re_Maxwell_Rule_17(c)_Subpoena_- _Prpsd_Redact.._[Govemment_Proposed_Redactions].pdf; 2021.04.05 JEISF_Reply_re_Maxwell_Rule_17(c)_Subpoent[Govemment_Proposed_Reda ctions].pdf; 2021.04.19_LAM_Joint_Letter_with_BSF_re_redactiontin_Rule_17_pleadingsiGovemm ent_Proposed_Redactions].pdf; 2021.04.02_Defts_Resp_to_BSF_Lth_Motn_to_Quash_Rule_17_SubiGovernment_Propos ed Redactions].pdf; Ex. A_2021.04.02_Defts_Resp_to_BSF_LM_Motn_to_Quash_Rule_17_Sub_- Prp;c1.._[Govemment_Proposed_Redactions].pdf Good morning, Attached please find a letter requesting certain redactions to filings regarding the defendant's application for a Rule 17(c) subpoena in the above-referenced case, which was just filed on ECF. In addition, attached p
Persons Referenced (4)
“...please find the Government's proposed redactions to the relevant filings from defense counsel and Boies Schiller Flexner LLP. Respectfully submitted, Assistant United Stat...”
United States“...nse counsel and Boies Schiller Flexner LLP. Respectfully submitted, Assistant United States Attorney Southern District of New York 1 St. Andrew% Plaza New York, NY 1000...”
United States Attorney“...nse counsel and Boies Schiller Flexner LLP. Respectfully submitted, Assistant United States Attorney Southern District of New York 1 St. Andrew% Plaza New York, NY 10007 EFTA00...”
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EFTA DisclosureRelated Documents (6)
Case 20-2413. Document 40. 08'20/2020. 2913550, Pagel of 74
Case 20-2413. Document 40. 08'20/2020. 2913550, Pagel of 74 20-2413 United States Court of Appeals for the Second Circuit Plaintlff-Appelke, —against— GHISLA1NE MAXWELL, Defendant-Appellant, SHARON CHURCHER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNOVICH MEDIA Intervenors. ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, 15-CV-7433 (LAP) Ghislaine Maxwell's Opening Brief Ty Gee Adam Mueller HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Den r 2 Tel. Attorneys for Defendant-Appellant Ghislaine Maxwell EFTA00075477 Case 20-2413, Document 40, 08/20/2020, 2913550, Page2 of 74 Table of Contents Table of Authorities iii Introduction 1 Jurisdictional Statement 2 Issues Presented 3 Statement of the Case and the Facts 3 The defamation action and the Protective Order 3 The motion to unseal and the first appeal 6 The remand, the arrest,
Case 9:08-cv-80893-KAM Document 214
Case 9:08-cv-80893-KAM Document 214 Entered on F LSD Docket 09/02/2010 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA FT. LAUDERDALE DIVISION Case No. 08-CIV-80893-MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT, JEFFREY EPSTEIN'S MOTION FOR PROTECTIVE ORDER AND OBJECTION TO DISCLOSURE OF CERTAIN DOCUMENTS WITH INTEGRATED MEMORANDUM OF LAW Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to a Joint Stipulation Regarding Certain Documentation files this his Motion for Protective Order and Objection to Disclosure of Certain Correspondence and Discovery for the reasons set forth below: I. PRELIMINARY STATEMENT During the underlying litigation, Epstein vigorously sought protection from the Court that these and other documents produced would be used for purposes other than those contemplated by the Federal Rules of Civil Procedure for discovery; i.e., dissemination in the
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel - EFTA00039421 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case 3 A. The NPA Does Not Bind the Southern District of New York 4 1. The Text of the Agreement Does Not Contain a Promise to Bind Other Districts 5 2. The Defendant Has Offered No Evidence That the NPA Binds Other Districts 9 B. The NPA Does Not Immunize Maxwell from Prosecution 15 1. The NPA Is Limited to Particular Crimes Between 2001 and 2007 15 2. The NPA Does Not Confer Enforceable Rights on Maxwell 17 C. The Defendant
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
Rol Slack lir „kite'
Rol Slack lir „kite' 2/949 Arcrwite a." 2434 7 Antai, Liu) 3 cut, , 4,/e EFTA00183732 KIRKLAND & ELLIS LLP AND AfilL/ArtO PART/H.3We; ' Cntercup Cantor 163 East 53'd Street New York, New York 10022-4611 WNW rwerA.COM September 2, 2008 VIA FACSIMILE (56D 820-8777 United States Attorney's Office Southern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Re:Jeffrey Bpstein Dear • Facsimile: In response to your letter dated August 26, 2008, I am confirming that Mr. Goldberger should continue to be listed as the contact pawn in the' mended victim notification letters and should receive the carbon copies of thoso letters as they are sent. • Also, we plan on speaking to Mr. Josofsberg this week to discuss a procedure for paying his fees. We intend to comply fully with the agreement and Mr. Epstein will pay Mr. Josfsberg's usual and customary hourly rates for his work pursuant to the agreement facilitating settlements unde
12/05/07 THU 15:25 FAX 305 530 5450
12/05/07 THU 15:25 FAX 305 530 5450 EXECUTIVE OFFICE sss TRANSMISSION OK TX REPORT sits TX/RX NO 3413 CONNECTION TEL 012125464900 SUBADDRESS CONNECTION ID ST. TIME 12/06 15:22 USAGE T 03'18 PCS. RESULT OK U.S. Department of Justice United States Attorney Southern District of" Florida UNITED STATES ATTORNEY'S OFFICE SOUTHERN DISTRICT OF FLORIDA 99 NE 4Th STREET MIAMI, FLORIDA 33132-2111 MEP Attorney Staff Assistant FACSIMILE TRANSMISSION COVER SHEET DATE: December 6, 2007 TO: Jay Leflcowitz, Esquire FAX NUMBER: SUBJECT: Epstein NUMBER OF PACES, INCLUDING THIS PAGE: 9 EFTA00214748 U.S. Department of Justice United States Attorney Southern District of Florida UNITED STATES ATTORNEY'S OFFICE SOUTHERN DISTRICT OF FLORIDA 99 NE 4Th STREET MIAMI, FLORIDA 33132-2111 Cyndee Campos Staff Assistant Attorney FACSIMILE TRANSMISSION COVER SHEET DATE: December 6, 2007 TO: Jay Lefkowitz, Esquire FAX NUMBER: SUBJECT: Epstein NUMBER OF PAGES, INCL
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