DataSet-9
EFTA00212319
2 pg
…on March
18, we will be filing a full, unredacted summary judgment motion under seal with Judge Marra and, for the public PACER
file, a summary judgment motion with quotations from the e-mails redacted.
We will be filing simultaneously…
DataSet-9
EFTA00040124
2 pg
… image002.jpg
Thanks, Jeff.
Brian, in light of Jeff's email, attached is the unredacted defense motion.
ns
hanks
i
From: Jeff Pagliuca
Sent: Wednesday, November 17, 2021 9:07 PM
To: Brian Burns
Cc: ceverdel >; Laura Menninger
Subject…
DataSet-9
EFTA01098114
11 pg
…PROFFER
GOVERNMENT CORRESPONDENCE IN SUPPORT OF CVRA CLAIMS
& GRANTING MOTION TO UNSEAL CORRESPONDENCE AND RELATED
UNREDACTED PLEADINGS OF PETITIONERS
THIS CAUSE is before the court on the petitioners' motion to use correspondence
generated between the United States Attorney's Office…
DataSet-9
EFTA01159278
10 pg
…AND JANE DOE #2'S MOTION TO USE CORRESPONDENCE TO
PROVE VIOLATIONS OF THE CRIME VICTIMS' RIGHT ACT AND TO HAVE
THEIR UNREDACTED PLEADINGS UNSEALED
COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims")…
DataSet-9
EFTA00215515
3 pg
…Petitioners,
Jane Doe #1 and Jane Doe #2, the complete, unredacted Non-Prosecution Agreement
between the United States and Jeffrey Epstein and any and all addenda, memoranda of
understanding, or similar documents that bear on the enforceability and meaning of…
DataSet-9
EFTA01081647
10 pg
…v.
UNITED STATES
JANE DOE 1 AND JANE DOE 2'S NOTICE OF INTENT TO COMPLY WITH COURT
ORDER DIRECTING FILING OF AN UNREDACTED MOTION AND
CORRESPONDENCE IN THE PUBLIC COURT FILE
COME NOW Jane Doe I and Jane Doe…
DataSet-9
EFTA00235238
10 pg
…AND JANE DOE #2'S MOTION TO USE CORRESPONDENCE TO
PROVE VIOLATIONS OF THE CRIME VICTIMS' RIGHT ACT AND TO HAVE
THEIR UNREDACTED PLEADINGS UNSEALED
COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims")…
DataSet-9
EFTA00208339
10 pg
…AND JANE DOE #2'S MOTION TO USE CORRESPONDENCE TO
PROVE VIOLATIONS OF THE CRIME VICTIMS' RIGHT ACT AND TO HAVE
THEIR UNREDACTED PLEADINGS UNSEALED
COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims")…
DataSet-9
EFTA00208438
10 pg
…AND JANE DOE #2'S MOTION TO USE CORRESPONDENCE TO
PROVE VIOLATIONS OF THE CRIME VICTIMS' RIGHT ACT AND TO HAVE
THEIR UNREDACTED PLEADINGS UNSEALED
COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims")…
DataSet-9
EFTA01199102
11 pg
…PROFFER
GOVERNMENT CORRESPONDENCE IN SUPPORT OF CVRA CLAIMS
& GRANTING MOTION TO UNSEAL CORRESPONDENCE AND RELATED
UNREDACTED PLEADINGS OF PETITIONERS
THIS CAUSE is before the court on the petitioners' motion to use correspondence
generated between the United States Attorney's Office…
DataSet-9
EFTA00212438
10 pg
…AND JANE DOE #2'S MOTION TO USE CORRESPONDENCE TO
PROVE VIOLATIONS OF THE CRIME VICTIMS' RIGHT ACT AND TO HAVE
THEIR UNREDACTED PLEADINGS UNSEALED
COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims")…
DataSet-9
EFTA00207967
9 pg
…DOE #1 AND JANE DOE #2'S REPLY TO GOVERNMENT'S RESPONSE TO
THEIR MOTION TO USE CORRESPONDENCE TO PROVE VIOLATIONS OF THE
CRIME VICTIMS' RIGHTS ACT AND TO HAVE THEIR UNREDACTED
PLEADINGS UNSEALED
COME NOW Jane Doe #1 and…
DataSet-9
EFTA00215409
3 pg
…Petitioners,
Jane Doe #1 and Jane Doe #2, the complete, unredacted Non-Prosecution Agreement
between the United States and Jeffrey Epstein and any and all addenda, memoranda of
understanding, or similar documents that bear on the enforceability and meaning of…
DataSet-9
EFTA00209256
5 pg
…that "...petitioners should not
comply with the Order Granting Petitioners' Motion to Proffer Government Correspondence in
Support of CVRA Claims & Granting Motion to Unseal Correspondence and Related
Unredacted Pleadings of Petitioners (DE 188) until further order of this Court."
2…
DataSet-9
EFTA00068410
3 pg
…Brian, in light of Jeff's email, attached is the unredacted defense motion.
Thanks.
From: Jeff Pagliuca
Sent: Wednesda November 17 2021 9:07 PM
To: Brian Burns
Cc: ceverdel ; Laura Menninger
Subject: (EXTERNAL] Re: Subpoena fod
…
DataSet-9
EFTA00211881
3 pg
…Petitioners,
Jane Doe #1 and Jane Doe #2, the complete, unredacted Non-Prosecution Agreement
between the United States and Jeffrey Epstein and any and all addenda, memoranda of
understanding, or similar documents that bear on the enforceability and meaning of…
DataSet-9
EFTA00596698
3 pg
…R.
Civ. P. 24(b), and requests that the Court unseal and make public and unredacted Defendant
Ghislaine Maxwell's Memorandum of Law in Support of Defendant's Motion for Summary
Judgment (ECF No. 541), Declaration of Laura A. Menninger…
DataSet-9
EFTA00209798
1 pg
…To: (USAFLS); (USAFLS)
Subject: Jane Does United States - Redacted Pleadings
Attached are the redacted motion to dismiss, motion to stay discovery (with attached unredacted RFP), and
reply in support of motion to dismiss (plus exhibits). Other than the motions to…
DataSet-9
EFTA00602807
11 pg
…PROFFER
GOVERNMENT CORRESPONDENCE IN SUPPORT OF CVRA CLAIMS
& GRANTING MOTION TO UNSEAL CORRESPONDENCE AND RELATED
UNREDACTED PLEADINGS OF PETITIONERS
THIS CAUSE is before the court on the petitioners' motion to use correspondence
generated between the United States Attorney's Office…
DataSet-9
EFTA00600054
15 pg
…PROFFER
GOVERNMENT CORRESPONDENCE IN SUPPORT OF CVRA CLAIMS
& GRANTING MOTION TO UNSEAL CORRESPONDENCE AND RELATED
UNREDACTED PLEADINGS OF PETITIONERS
THIS CAUSE is before the court on the petitioners' motion to use correspondence
generated between the United States Attorney's Office…