giuffre-maxwell
gov.uscourts.nysd.447706.1320.8
12 pg
…specifically identified both Kellen and Marcinkova as among four named “potential co-
conspirators of Epstein” in the non-prosecution agreement it executed with Epstein as part of his
guilty plea to Florida state sex offense charges. See Non-Prosecution Agreement…
giuffre-maxwell
1320-8
12 pg
…specifically identified both Kellen and Marcinkova as among four named “potential co-
conspirators of Epstein” in the non-prosecution agreement it executed with Epstein as part of his
guilty plea to Florida state sex offense charges. See Non-Prosecution Agreement…
giuffre-maxwell
gov.uscourts.nysd.447706.773.4
5 pg
…prosecute
Epstein or his employees on federal charges contained in a 53-page
indictment. A 2007 federal non-prosecution agreement with Epstein states,
among other things, that he …
giuffre-maxwell
gov.uscourts.nysd.447706.936.0
21 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…her are from 25 years ago, calling the indictment 'an effort to dance around' the
controversial non-prosecution sweetheart deal Epstein and his associates received in
Florida in 2007.
With her bail now denied, Maxwell will return to the Metropolitan…
giuffre-maxwell
gov.uscourts.nysd.447706.20.0
26 pg
…Notification Letter. Indeed, Epstein entered into a non-
prosecution agreement with the federal authorities obligating him to pay restitution for his crimes
against Ms. Giuffre. That agreement also protected any “co-conspirators” from prosecution.
The remaining question, then, is whether…
giuffre-maxwell
gov.uscourts.nysd.447706.160.0
12 pg
…specifically identified both Kellen and Marcinkova as among four named “potential co-
conspirators of Epstein” in the non-prosecution agreement it executed with Epstein as part of his
guilty plea to Florida state sex offense charges. See Non-Prosecution Agreement…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.7
9 pg
…Dame, Miami Beach, FL 33141
NON PARTY (VR) 000247
GIUFFRE00093 5
Case 1:15-cv-07433-LAP Document 1320-7 Filed 01/03/24 Page 3 of 9
…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.31
10 pg
…or his associates.
12 BY MR. EDWARDS:
13 Q. What -- what types of persuasions did Alan
14 Dershowitz use in an attempt to dissuade the
15 prosecution of Alan Dershowitz [sic] or his
16 associates?
17 MR. PAGLIUCA: Object to…
giuffre-maxwell
1320-7
9 pg
…Dame, Miami Beach, FL 33141
NON PARTY (VR) 000247
GIUFFRE00093 5
Case 1:15-cv-07433-LAP Document 1320-7 Filed 01/03/24 Page 3 of 9
…
giuffre-maxwell
gov.uscourts.nysd.447706.1118.0
21 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…121 (2d Cir. 2006). We
observe that our holding in Lugosch relies on the general principle that parties may
“be assumed to have supported their papers with admissible evidence and non‐
frivolous arguments.” Id. at 122. Insofar as a district…
giuffre-maxwell
gov.uscourts.nysd.447706.116.0
6 pg
…Ms. McCawley, on April 11, 2016, filed a pleading in
Broward County, Florida court captioned: “Plaintiffs and Non-Party Virginia Giuffre’s Notice
Regarding the Parties’ Joint Stipulation of Dismissal.” Menninger Decl. at Ex. B. In that
pleading, Messrs. Cassell…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…121 (2d Cir. 2006). We
observe that our holding in Lugosch relies on the general principle that parties may
“be assumed to have supported their papers with admissible evidence and non‐
frivolous arguments.” Id. at 122. Insofar as a district…
giuffre-maxwell
gov.uscourts.nysd.447706.978.0
27 pg
…121 (2d Cir. 2006). We
observe that our holding in Lugosch relies on the general principle that parties may
“be assumed to have supported their papers with admissible evidence and non‐
frivolous arguments.” Id. at 122. Insofar as a district…
giuffre-maxwell
gov.uscourts.nysd.447706.977.0
27 pg
…121 (2d Cir. 2006). We
observe that our holding in Lugosch relies on the general principle that parties may
“be assumed to have supported their papers with admissible evidence and non‐
frivolous arguments.” Id. at 122. Insofar as a district…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.17
13 pg
…preparation to litigate Ms. Giuffre’s factual allegations, the parties
sought and obtained from each other and non-parties a wide range of highly sensitive, personal
and confidential information about themselves and non-parties.
This Protective Order. To facilitate disclosures…
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…1122].) Defendant Ghislaine Maxwell
(“Ms. Maxwell”) and non-party John Doe (“Doe”) have opposed the
USVI’s motion. (See Defendant Ghislaine Maxwell’s Memorandum of
Law in Opposition to USVI Ex Parte Motion to Intervene and for
Confidential Access to…
giuffre-maxwell
gov.uscourts.nysd.447706.957.0
13 pg
…preparation to litigate Ms. Giuffre’s factual allegations, the parties
sought and obtained from each other and non-parties a wide range of highly sensitive, personal
and confidential information about themselves and non-parties.
This Protective Order. To facilitate disclosures…
giuffre-maxwell
gov.uscourts.nysd.447706.755.0
75 pg
…The plaintiff here, her lawyers and the plaintiff,
16 have sought to revoke Mr. Epstein's nonprosecution agreement,
17 which is the primary basis for his invocation of the Fifth
18 Amendment privilege. They can withdraw that, and that then…
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