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that, "while not the equivalent of criminal ex post facto, nevertheless would run afoul of Landgraf s considerations, and that he "expect[ed] that the Supreme Court's future decisions" would confirm such a reading. Thom v. Ashcroft, 369 F.3d 158, 163 n.6 (2d Cir. 2004) (Calabresi, J., "[s]peaking only for [him]sel
ng of Maxwell's Depositions Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April 2016 deposition transcript. (See 15 Civ. 7433 (LAP), Dkt.
met that standard." (Id. at 7) (emphasis in original). 8. Unsealing of Maxwell's Depositions Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April
d. at 538-39. "[L]ess drastic measures ... such as limiting instructions, 52 While Zafiro involved a motion to sever defendants, rather than counts, the Supreme Court's construction of Rule 14(a) applies in either case. See Page, 657 F.3d at 129 (relying on Zafiro); United States v. Gracesqui, No. 10 Cr. 74 (PKC),
irc ompe "unalMer eluded e Govan nut that ed to hasis in 8. Unsealing of Maxwell's Depositions v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judgg Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April
ing, and related to, Maxwell's April 74 EFTA00100041 2016 deposition transcript. (See 15 Civ. 7433 (LAP), Dkt. No. 1077). Maxwell appealed Judge Preska's order, arguing that the court abused its discretion in ordering the unsealing of the deposition materials and that Maxwell's interests outweighed
. at 538-39. "[L]ess drastic measures . .. such as limiting instructions, 52 While Zafiro involved a motion to sever defendants, rather than counts, the Supreme Court's construction of Rule 14(a) applies in either case. See Page, 657 F.3d at 129 (relying on Zafiro); United States v. Gracesqui, No. 10 Cr. 74 (PKC),
8. Unsealing of Maxwell's Depositions Three months after Chief Judge McMahon issued her Order, Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April
ge McMahon issued her Order, Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April 74 EFTA00077706 2016 deposition transcript. (See 15 Civ
. at 538-39. "[L]ess drastic measures . .. such as limiting instructions, 52 While Zafiro involved a motion to sever defendants, rather than counts, the Supreme Court's construction of Rule 14(a) applies in either case. See Page, 657 F.3d at 129 (relying on Zafiro); United States v. Gracesqui, No. 10 Cr. 74 (PKC),
8. Unsealing of Maxwell's Depositions Three months after Chief Judge McMahon issued her Order, Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April
ge McMahon issued her Order, Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April 74 EFTA00039521 2016 deposition transcript. (See 15 Civ
d. at 538-39. "[L]ess drastic measures ... such as limiting instructions, 52 While Zafiro involved a motion to sever defendants, rather than counts, the Supreme Court's construction of Rule 14(a) applies in either case. See Page, 657 F.3d at 129 (relying on Zafiro); United States v. Gracesqui, No. 10 Cr. 74 (PKC),
inal). 8. Unsealing of Maxwell's Depositions Three months after Chief Judge McMahon issued her Order, v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April
ief Judge McMahon issued her Order, v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April 74 EFTA00103099 2016 deposition transcript. (See 15 Civ
"confidential" materials simultaneous with the criminal prosecution. Nixon v. Warner Commc'ns, 435 U.S. 589 (1978), is the closest, yet even there, the U.S. Supreme Court refused press access to the tapes obtained from third parties played in the criminal trial while the matter remained on appeal. That Ms. Maxwell d
tigated; Ms. Maxwell is not asking this Court to decide that question today. But Ms. Maxwell is seeking in both the Second Circuit and before Judge Preska that the status quo be maintained until the issue can be litigated. If, for example, without the benefit of this information, the Second Circuit an
the counts would waste judicial resources by requiring a second trial at 53 While Zafiro involved a motion to sever defendants, rather than counts, the Supreme Court's construction of Rule 14(a) applies in either case. See Page, 657 F.3d at 129 (relying on Zafiro); United States v. Gracesqui, No. 10 Cr. 74 (PKC),
materials. Giuf•e v. Maxwell, No. 20-2413 (2d Cir.) (Dkt. No. 140-1 at 2). On October 19, 2020, the Second Circuit found that Judge Preska "correctly held that the deposition materials are judicial documents to which the presumption of public access attaches, and did not abuse its discr
Entities connected to both Supreme Court and Loretta A. Preska

Jeffrey Epstein
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Donald Trump
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United States
LOCATION
Julie K. Brown
PERSONLeon Black
PERSON
George W. Bush
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Ghislaine Maxwell
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Department of Justice
ORGANIZATION
Prince Andrew
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Scarlett Johansson
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Wilbur Ross
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Virginia Giuffre
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Colorado
LOCATIONChris Dilorio
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Joe Biden
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Bill Clinton
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Michael Cohen
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Bloomberg L.P.
ORGANIZATIONthe Southern District
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Samantha Power
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