Case 1:15-cv-07433-LAP Document 1111 Filed 09/01/20 Page 1 of 14 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-LAP THE GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' MEMORANDUM OF LAW IN SUPPORT OF EX PARTE MOTION TO INTERVENE AND FOR CONFIDENTIAL ACCESS TO JUDICIAL RECORDS AND DISCOVERY DOCUMENTS The Government of the United States Virgin Islands (the "USVI") moves to intervene in this action for the limited purpose of obtaining confidential access to both: (a) all sealed documents related to the parties' motions for summary judgment [ECF No. 540 to 543, 586 to 586-3, 620 to 621, and 872]; and (b) all unfiled discovery deposition transcripts and exhibits thereto. The USVI seeks to modify the Protective Order [ECF No. 62] solely to be granted confidential access to these materials, and, if granted access, agrees to be bound by the Protective Order. The USVI seeks confidential access to these sealed documents and unfiled discovery materials because they are very likely relevant to its pending Virgin Islands Criminally Influenced and Corrupt Organizations Act ("CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities before the Superior Court of the U.S. Virgin Islands. See Exhibit A hereto (USVI's operative First Amended Complaint, filed February 11, 2020). Access to other judicial documents in this action has already been granted to intervening private parties in interest, see Brown v. Maxwell, 929 F.3d 41 (2d Cir. 2019), and also is the subject of ongoing litigation before this Court. See, e.g., ECF No. 1096-1108. The 1 EFTA00073260