EFTA00086685.txt

"Br. for Pl.-Appellee Virginia L. Giuffre, Giuffre v. Maxwell"

"Giuffre v. Maxwell"

"The Protective Order entered by Judge Sweet"

"Maxwell specifically mentioned "the specter of some theoretical prosecution" when arguing in support of the entry of her version of the Protective Ord"

"the matters that were the subject of the Giuffre Action"

"I cannot possibly second guess how Judge Sweet ran this litigation"

"the Government has advised the Court that it contacted Boies Schiller as part of its search for parties who might have been victims"

"the record shows that Giuffre likely could not have secured Maxwell's deposition"

"kept the agreement secret from Epstein's victims"

"Boies Schiller represented the plaintiff in the litigation, and continues to represent her on a pending post-settlement appeal"

"entered by the late Hon. Robert W. Sweet in a civil defamation action, Giuffre v. Maxwell"

"In September 2015, Virginia L. Giuffre commenced a civil suit against Ghislaine Maxwell"

"Virginia L. Giuffre commenced a civil suit against Ghislaine Maxwell, alleging that Maxwell had defamed Giuffre"

"Virginia L. Giuffre commenced a civil suit against Ghislaine Maxwell"

"The Giuffre Action was settled and dismissed with prejudice pursuant to a joint stipulation for dismissal on May 25, 2017"

"alleging that Maxwell had defamed Giuffre by stating that Giuffre was not the victim of sex crimes perpetrated by, among others, Maxwell and Jeffrey E"

"alleging that Maxwell had defamed Giuffre by stating that Giuffre was not the victim of sex crimes perpetrated by, among others, Maxwell and Jeffrey E"

"it has filed papers on behalf of Giuffre, in both the district and appellate proceedings"

"legitimate privacy concerns on the part of both Giuffre and Maxwell"

"legitimate privacy concerns on the part of both Giuffre and Maxwell"

"assembl[ed] a large, cult-like network of underage girls—with the help of young female recruiters (including Maxwell)"

"criminal activity against Maxwell and Epstein was a thing of the past... [referencing] underage girls... whom he coerced into performing sex acts"

"The deal also included a non-prosecution agreement with the Department of Justice, which immunized Epstein"

"the Giuffre Action was litigated entirely almost under seal"

"caused the Government to proceed via subpoena [to Boies Schiller]"

"Giuffre's obligations thereunder were triggered at the time of settlement"

"Maxwell refused to agree to any Protective Order containing a provision... permitting the production of confidential materials to law enforcement"

"Giuffre and Boies Schiller agreed to it"

"Giuffre or Boies Schiller had anything to do with the Government's decision"

"as the case settled, it appears to me to bind the parties permanently"

"the extraordinary amount of publicity surrounding all aspects of what I will call the Epstein matter... gives Maxwell the degree of protection that co"