EFTA00011520.pdf

Type: pdf
Source set: data-set-8

Extracted text

U.S. Department of .1 ustice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
February 28, 2019
TO BE FILED UNDER SEAL
VIA EMAIL
The Honorable Sarah Netburn
United States District Court
Southern District of New York
United States Courthouse
New York, New York 10007
Re:
In re Application to Unseal Civil Discovery Materials, USAO No. 2018R01618
Dear Judge Netburn:
The Government writes respectfully in connection with its sealed application and proposed
order pursuant to the All Writs Act, Title 28, United States Code, Section 1651, for a limited order
to unseal discovery materials in the possession of Boies Schiller & Flexner LLP
(the "Application"), in connection with the matter Jane Doe 43 v. Epstein, et aL ("Jane Doe"),
17 Civ. 616 (JGK) (SN) (the "Litigation"), a copy of which is attached hereto as Exhibit A.
Background
As described in the Application, the Government has served a grand jury subpoena
(the "Subpoena") upon Boies Schiller & Flexner ("Boies Schiller") requiring the production of
copies of discovery and related materials related to the Litigation. The Subpoena was validly
issued pursuant to an ongoing investigation into Jeffrey Epstein and others, for possible violations
of Title 18, United States Code, Sections 1591 and 1594(c) (unlawfully trafficking minors) and
Section 2422(b) (unlawfully enticing minors) (the "Investigation"). The production of materials
pursuant to the Subpoena is solely for the purposes of the Investigation, and is subject to the
protections and restrictions of Fed. R. Crim. P. 6(e).
The Government has been advised that Boies Schiller, which is counsel for plaintiffs in the
Litigation, does not intend to contest the Subpoena. However, the Government is advised that
although Boies Schiller would not otherwise contest compliance with the Subpoena, it believes
that a protective order entered in the Litigation (the "Pr…

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