giuffre-maxwell
gov.uscourts.nysd.447706.1122.0_2
13 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.20.0
26 pg
…BSJ/HBP), 2010 WL 5297756 (S.D.N.Y. Dec. 21, 2010) ..........................16
Celle v. Felipino Reporter Enterprises Inc.
209 F. 3d 163 (2d Cir. 2000) .....................................................................................................11
Chesney v. Valley Stream Union Free Sch. Dist.,
236 F.R.D. 113 …
giuffre-maxwell
gov.uscourts.nysd.447706.1295.16
22 pg
…s
afore,mentioned criminal and illegal enterp,rise operatd although it was at least
continuously and actively in operation from the mid-1990's through and including
the calendar year 2007.
24. Defendant Epstein has continued the enterprise and conspiracy…
giuffre-maxwell
gov.uscourts.nysd.447706.561.0
22 pg
…In that motion, Ms. Giuffre alleged that she had
been sexually trafficked by Jeffrey Epstein to his friends, including Epstein’s close friend and
criminal defense attorney, Alan Dershowitz. Thereafter, Dershowitz repeated attacked Edwards
and Cassell’s professionalism in a…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…The victims specifically alleged that Reinhart had “joined Epstein’s
payroll shortly after important decisions were made limiting Epstein’s criminal liability” and that
Reinhart had gone on to improperly represent Epstein-related witnesses in various civil suits.
See DE…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.22
22 pg
…1:15-cv-07433-LAP Document 1328-22 Filed 01/05/24 Page 2 of 22
PALM BEACH COUNTY SHERIFF'S OFFICE
CENTRAL RECORDS
MPTIONS/CONFIDENTIAL
r 1'19.…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.21
19 pg
…Case 1:15-cv-07433-LAP Document 1328-21 Filed 01/05/24 Page 2 of 19
PALM BEACH COUNTY SHERIFF'S OFFICE
CENTRAL RECORDS
MPTIONS/CONFIDENTIAL
C …
giuffre-maxwell
gov.uscourts.nysd.447706.1078.1
8 pg
…Case No. 20 Cr. 330 (AJN), Local Criminal Rule 23.1
Dear Judge Nathan,
On behalf of our client, Ghislaine Maxwell, we write to request that the Court enter an
order prohibiting the Government, its agents and counsel for witnesses…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.0
35 pg
… 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…
giuffre-maxwell
gov.uscourts.nysd.447706.363.0
18 pg
… I am a Professor of Law, Emeritus, at Harvard Law School, where I taught
criminal law, legal ethics and other subjects for 50 years. As a criminal defense attorney, I have
also represented numerous individuals accused of crimes over the…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…DOC 291 thoroughly outlines: (1) The relationship
between Dershowitz and Epstein; (2) Dershowitz's role representing Epstein during the criminal
investigation of Epstein; (3) Dershowitz's role in negotiating the Non-Prosecution Agreement
("the NPA") between Epstein and the United…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.2
12 pg
…a
police report?
A. I am aware there is a police report.
Q. You are aware there was a criminal investigation of Jeffrey Epstein?
A. I am aware that there was that.
Q. Now that you are aware of those…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.42
9 pg
…accusations.
Let's bring in Paul Callan. He's a CNN legal analyst, criminal defense attorney and
former prosecutor to talk about all this, also former prosecutor Wendy Murphy will
join. She's an adjunct professor of sexual violence at…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
… Annoyance, embarrassment, oppression, undue burden (“Privacy Interests”) (“CI-
3”).
4. Preserving the fundamental rights of suspects or others under criminal
investigation (“CI-4”).
5. Improper submission of documents thereby weaponizing judicial documents (“CI-
…
giuffre-maxwell
gov.uscourts.nysd.447706.562.1
13 pg
…Florida.
12. In the NPA, the United States additionally agreed that it would not institute any
federal criminal charges against any potential co-conspirators of Epstein.
13. As a co-conspirator of Epstein, Maxwell was consequently granted immunity in
the…
giuffre-maxwell
gov.uscourts.nysd.447706.57.3
39 pg
…Railways Board [1980] AC 521 and were covered by litigation privilege.
Their evidence was that it was expected that civil and criminal proceedings might
be brought against them and that the dominant purpose of the investigations
was to identify the…
giuffre-maxwell
gov.uscourts.nysd.447706.773.4
5 pg
…Scarola said.
Still, the spectacle of a U.S. president being drawn into sordid litigation involving a notorious politically connected
sexual criminal who got an apparent sweetheart deal from then-Miami U.S. Attorney Alex Acosta, now Trump’s
nominee…
giuffre-maxwell
gov.uscourts.nysd.447706.1.0
12 pg
…Florida.
12. In the NPA, the United States additionally agreed that it would not institute any
federal criminal charges against any potential co-conspirators of Epstein.
13. As a co-conspirator of Epstein, Maxwell was consequently granted immunity in
the…
giuffre-maxwell
gov.uscourts.nysd.447706.24.1
13 pg
…Florida.
12. In the NPA, the United States additionally agreed that it would not institute any
federal criminal charges against any potential co-conspirators of Epstein.
13. As a co-conspirator of Epstein, Maxwell was consequently granted immunity in
the…
giuffre-maxwell
gov.uscourts.nysd.447706.1155.0_2
13 pg
…alleged
“Countervailing Interests” identified by Ms. Maxwell—all of which are without merit. See Dkt.
1067.
Case 1:15-cv-07433-LAP Document 1155 Filed 11/19/20 Page 3 of 13
criminal matter, this Court held, “[a]gain…