…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 States; (4) Facts inferring that Dershowitz was aware of Epstein's…
…1). Generally, they allege that the respondent Government violated their rights under the CVRA by failing to consult with them before negotiating a non-prosecution agreement with Jeffrey Epstein, who subjected them to various sexual crimes while they were minors. …
…1). Generally, they allege that the respondent Government violated their rights under the CVRA by failing to consult with them before negotiating a non -prosecution agreement with Jeffrey Epstein, who subjected them to various sexual crimes while they were minors. …
…1). Generally, they allege that the respondent Government violated their rights under the CVRA by failing to consult with them before negotiating a non-prosecution agreement with Jeffrey Epstein, who subjected them to various sexual crimes while they were minors. …
…1). Generally, they allege that the respondent Government violated their rights under the CVRA by failing to consult with them before negotiating a non-prosecution agreement with Jeffrey Epstein, who subjected them to various sexual crimes while they were minors. …
…21, 26-27. Ms. Maxwell was not a party to any of those litigations: not the criminal case against Mr. Epstein (Compl. ¶ 14), any non-prosecution agreement between Mr. Epstein and the U.S. Attorney’s Office (Compl. ¶¶ 11-13)…
…the Crime Victims Rights Act, 18 U.S.C. § 3771 (“CVRA”), 2 a non-prosecution agreement between Mr. Epstein and the U.S. Attorney’s Office for the Southern District of Florida that is almost nine years old. Through counsel…
…defense team, and the ultimate decision by the U.S. Attorney's Office to sign a non-prosecution agreement that was negotiated in secret and sealed in return for a guilty plea to a lesser state crime. The deal, which…
…805-0300 Case 1:15-cv-07433-LAP Document 31 Filed 01/28/16 Page 9 of 22 9 G1ETGIUA 1 co-conspirators were also part of that plea agreement, that 2 non-prosecution agreement, and were not prosecuted…
…1). Generally, they allege that the respondent Government violated their rights under the CVRA by failing to consult with them before negotiating a non-prosecution agreement with Jeffrey Epstein, who subjected them to various sexual crimes while they were minors. …
…to join a long-running Crime Victims’ Rights Act (“CVRA”) lawsuit, which was brought by other young girls who were also abused, and sought to challenge Jeffrey Epstein’s non-prosecution agreement which also pardoned co-conspirators. Through lawyers1, Ms…
…your 19 his potential criminal liability and your 20 questions, we can use the full invocation 20 intention to seek to rescind his 21 that we did in response to your first 21 non-prosecution agreement, the admissions 22 question…
…your 19 his potential criminal liability and your 20 questions, we can use the full invocation 20 intention to seek to rescind his 21 that we did in response to your first 21 non-prosecution agreement, the admissions 22 question…
…of deposition testimony and lawyer vitriol into 1 The Countervailing Interests include: 1. Reasonable reliance on the Protective Order by a party or non-party (“CI-1”). 2. Prevention of the abuse of court records and files (“CI-2”).1 …
…story to the media; second, her tactical plan to bully potential witnesses into silence by inappropriate threat of criminal prosecution. The Court should reject the “non-protective” order proposed by Plaintiff and enter the reasonable, and enforceable, order submitted by…
…2013), are inapposite. In Silver, the court noted that the non-parties had “not otherwise been connected to or named in Defendant’s criminal prosecution.” 2016 WL 1572993, at *6. Here, Doe 144 has been publicly connected to Plaintiff’s…
…deny that any countervailing interests exist, and protest that Ms. Maxwell’s numerous proposed countervailing interests, and those of yet unheard-from Non- Parties, cannot possibly rebut the presumption of public access. Because their Responses ignore both the law and…
…2020 ruling concluding that the transcripts of Ms. Maxwell’s April 2016 deposition and Doe 1’s deposition should be unsealed in their entirety (with the exception of non-party names). We recognize that a reconsideration motion is an extraordinary…
…in their pleadings and cannot satisfy it. ARGUMENT I. THE GOVERNMENT CANNOT INTERVENE OR MODIFY THE PROTECTIVE ORDER FOR ACCESS TO NON-JUDICIAL DISCOVERY MATERIALS The Government buries the lead in its Motion. It first seeks four sets of documents…
…at 77). A subpoena is overbroad when the government fails to make a “reasonable effort to request only those documents that are relevant and non- privileged, consistent with the extent of its knowledge about the matter under investigation.” Id. Here…
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