…872); (e) All currently unfiled discovery deposition transcripts and exhibits thereto in this action. The USVI expects that these sealed documents and unfiled discovery contain critical information related to Epstein’s criminal enterprise in the Virgin Islands and beyond…
…ARGUMENT A. The USVI Has Compelling Need for Access to Jeffrey Epstein’s and Other Witnesses’ Depositions. The USVI alleges in its CICO action that Epstein created and participated in a criminal sex trafficking enterprise in the Virgin Islands, wherein…
…Stuart, 427 U.S. 539 (1976) ............................................................................................................................. 10 Nixon v. Warner Commc'ns, Inc., 435 U.S. 589 (1978) ............................................................................................................................. 10 Pre…
… Salas by Salas v. Wang, 846 F.2d 897 (3d Cir. 1988)...................................................................................................... 11 U.S. Underwriters Ins. Co. v. LCRF Enterprises, LLC, No. 10-CV-3418 GBD, 2012 WL 993502 (S.D.N.Y. Mar. 26, 2012)...................................... 11 Fifth Amendment…
…January 21, 20l51Z:O1PK4 To: Gmax I have never been a party in any criminal action pertaining to JE Every story in the press innuendo and comment has been taken from civ depositions against JE, which were settled many years…
… The Discovery disclosed to the defendant (“Defendant”) and/or to the defendant’s criminal defense attorneys (“Defense Counsel”) during the course of proceedings in this action: a) Shall be used by the Defendant or her Defense Counsel solely for purposes…
… I have never been in a suit criminal or civil and want it to stay that way. The US lawyers for the Jane Does are filling additional discovery motions and if I speak I open my self to being part…
…3 unsealing or whose time to object argument of counsel violative of C1-4 to unsealing has not yet expired. Local Criminal Rule 23.1.…
… Maxwell’s Argument Regarding Third-Party Reliance is Meritless. ..............................6 III. Maxwell’s Argument About Her Right to a Fair Criminal Trial Was Raised and Rejected on Appeal. ...............................................................................................8 IV. M…
…materials” to the Defendant for the following reasons: For months Ms. Maxwell has been requesting documents from the Plaintiff relating to her claim that there is an ongoing and active criminal investigation in which Ms. Maxwell is a target. First…
…the Court’s Order [DE 134] dated May 2, 2016.1 ARGUMENT Statements made by witnesses to law enforcement are protected by the public interest privilege, which “exists to encourage witnesses to come forward and provide information in criminal investigations . . …
…or in the Alternative Modification of the Protective Order. 3. I am the Ronald N. Boyce Presidential Professor of Criminal Law and University Distinguished Professor of Law at the S.J. Quinney College of Law, where I teach criminal procedure…
…2 231 6.20.16 information, and argument of C1-3 counsel violative of Local C1-4 Criminal Rule 23.1. C1-1 …
…to promote her sham non-profit, Victims Refuse Silence, Inc. 2. No law enforcement agency pursued any criminal charges against Ms. Maxwell, even after both federal and state investigators fully scrutinized Ms. Maxwell’s one-time 1 emp…
…Embarrassment, Oppression, and Undue Burden” Do Not Warrant Continued Sealing. ............................................................................................................ 13 F. A Criminal Investigation Does Not Warrant Continued Sealing.............................. 14 V. The Cour…
…and much of the information that non-parties seek to keep sealed, have already been presented to a jury at a public criminal trial where only minor victims were permitted to testify under a pseudonym. See United States v. Maxwell…
…seal records concerning underage victims – well beyond replacing their names with initials – and victims do not forego their rights to privacy merely because they have played a role in a civil or criminal case against perpetrators. As an initial matter…
…cs Codo, Sections 1591(aX1) and 2; and IT APPEARING that Epstein seeks to resolve globally his state and federal criminal liability and Epstein undentands and acknowledges that, in exchan&e for the benefits provided by this agreement, he agrees…
…FILED Court Keep sealed – Non-Party reliance on ordered other Protective Order & Release of inadmissible CI-1; CI-2; excerpts information in violat…
…round one of unsealing) on this Court’s analysis in this round two, and the impact of any unsealing on Ms. Maxwell’s pending criminal trial. Ms. Maxwell also needed to address plaintiff’s request to keep certain items under…