Epstein Secrets

adioactive Material Users, Inc. v. Griepentrog, passim 945 F.2d 150 (6th Cir. 1991) 14 Mohammed v. Reno, 309 F.3d 95 (2d Cir. 2002) 13, 15, 25 Nixon a Warner Communications, Inc., 435 U.S. 589 (1978) 18, 19, 20 Nken v. Holder, 556 U.S. 418 (2009) 27 Patterson v. Colorado ex rel. Attorney Gen

to Stay Pending Appeal or, in the Alternative, Motion for a Temporary Administrative Stay Pending Full Consideration of the Motion to Stay Ty Gee Laura Menninger Adam Mueller Z1LLUI JW llyt/Gtialtt Llftt-1lLttliG EFTA00074904 Case 20-2413. Document 10-1, 07/30/2020, 2896538, Page3 of 38 Table of Conte

1068 & 1068-1) EXHIBIT 6: June 24, 2020 Response by Miami Herald (Dist. Ct. Doc. 1067) EXHIBIT 7: July 1, 2020 Reply by Ms. Maxwell & Decl. by Ms. Menninger in Support Thereof (Dist. Ct. Docs. 1073, 1074, and 1074-1, 1074-2, 1074-3, 1074-4) EXHIBIT 8: Transcript of July 23, 2020 Hearing EXHIBIT 9: July

t to the sound discretion of the trial court, a discretion to be exercised in light of the relevant facts and circumstances of the particular case." Nixon v. Warner Commtans, Inc., 435 U.S. 589,599 (1978). The panel lacks the context and familiarity with the facts, the parties and the non-parties to a

onsidered and vacated. 25 EFTA00791894 Case 18-2868, Document 141, 03/15/2019, 2519388, Page27 of 27 Respectfully submitted, s/ Ty Gee Ty Gee Laura Menninger Adam Mueller HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 Tel 303.831.7364 [email protected]; [email protected]; a

to exercise its sound discretion whether to seal or redact the materials "in light of the relevant facts and circumstances of the particular case," Nixon v. Warner Commc 'ns, Inc., 435 U.S. 589, 599 (1978). II. General objections to unsealing of summary judgment materials. As an initial matter, it i

udge Marra /172 Proposed Redactions: Statement of Undisputed Facts 11- 17 and 35-52 10 EFTA00794224 Respectfully submitted, s/ Ty Gee Ty Gee Laura Menninger Adam Mueller HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 Tel 303.831.7364 [email protected]; [email protected];

lligence community faced "greater challenges" in briefing former President Trump than it had confronted in almost five decades, when President-elect Nixon was taking office, according to a new account published by the CIA's internal research center. According to the article, the briefings during the t

ic detail on Tuesday about the alleged encounters in the 1990s, portraying Maxwell as an active participant. The article noted that defense attorney Laura Menninger confronted the woman with FBI documents from 2019 and 2020, saying she had told the government her memory was foggy on whether Maxwell was present

atify private spite or promote public scandal" or "serve as reservoirs of libelous statements for press consumption." Brown, 929 F.3d at 51 (quoting Nixon v. Warner Commc'ns, Inc., 435 U.S. 589, 598 (1978)). The Brown court held: "District courts should exercise the full range of their substantial pow

15-cv-07433-LAP Ms. Maxwell's Objections to Unsealing Docket Entries 143. 173. and 199 and to Unsealing Docket Entries 164 and 230 at This Time. Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 EFTA00075004 CageaUlg0caAIDer0dthhilfii igl5

ated that in deciding whether to unseal materials it was important to give weight to the impact on a criminal defendant's right to a fair trial. In Nixon v. Warner Communications, Inc., 435 U.S. 589 (1978), a number of media moved the district court to release audio tapes admitted into evidence in the

401 East Las Olas Blvd., Suite 1200 Fort Lauderdale, Florida 33301 Telephone: (954) 356-0011 Facsimile: (954) 356-0022 FACSIMILE COVER SHEET TO: Laura Menninger, Esq. Haddon, Morgan and Foreman, P.C. Fax No. Telephone No. 303.832.2628 301831.7364 FROM: Sigrid S. McCawley, Esq. DATE: February 26, 2016

, By: Paul G. Cassell, Esq. Counsel for Defendant Ghislaine Maxwell: HADDON, MORGAN AND FOREMAN, P.C., 150 East 10th Avenue, Denver, CO 80203, By: Laura A. Menninger, Esq., Jeffrey S. Pagliuca, Esq., Ty Gee, Esq. Counsel for Intervenor Michael Cemovich: RANDAZZA LEGAL GROUP, PLLC, 100 Pearl Street, 14th Floor,

ch as using records "to gratify spite or promote scandals" or where files might serve "as reservoirs of libelous statements for press consumption." Nixon v. Warner Commcins, Inc., 435 U.S. 589, 598, 98 S.Ct. 1306, 55 L.Ed.2d 570 (1978); see also Amodeo II, 71 F.3d at 1051 (internal quotation marks an

15-cv-07433-LAP \ Is. Maxwell's Objections to Unsealing Docket Entries 143, 173, and 199 and to Unsealing Docket Entries 164 and 230 at This Time. Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 303.831.7364 EFTA00022960 --- PAGE BREAK -

atify private spite or promote public scandal" or "serve as reservoirs of libelous statements for press consumption." Brown, 929 F.3d at 51 (quoting Nixon v. Warner Commens, Inc., 435 U.S. 589, 598 (1978)). The Brown court held: "District courts should exercise the full range of their substantial powe