EFTA00011520.pdf

"Jane Doe 43 v. Epstein, et aL (Jane Doe), 17 Civ. 616 (JGK) (SN) (the Litigation)"

"Dear Judge Netburn: ... in connection with the matter Jane Doe 43 v. Epstein, et aL"

"Boies Schiller, which is counsel for plaintiffs in the Litigation"

"the Government has served a grand jury subpoena (the Subpoena) upon Boies Schiller & Flexner"

"The Government writes respectfully in connection with its sealed application ... to unseal discovery materials"

"GE a FFREY S. BERMAN ... Assistant United States Attorney"

"Jane Doe 43 v. Epstein, et aL (Jane Doe), 17 Civ. 616 (JGK) (SN) (the Litigation)"

"extraordinary circumstances of the Government's Investigation and Application"

"should this Court permit Boies Schiller to respond, Boies Schiller would have the right to move to quash—including, for example, if a grand jury subpo"

"the Government notes that any materials produced pursuant to a grand jury subpoena fall under the protections and restrictions set forth in Fed. R. Cr"

"investigation into Jeffrey Epstein ... for possible violations of Title 18, United States Code, Sections 1591"

"neither Epstein nor other subjects of the investigation are believed to be similarly aware"

"neither Epstein nor other subjects of the investigation are believed to be similarly aware... [of the investigation relative to the] Litigation"

"Assistant United States Attorney"

"the Government respectfully requests that the Court grant the Application. ... Not so with respect to the Litigation"

"the Government respectfully requests that the Court grant the Application ... Respectfully submitted, GE a FFREY S. BERMAN"