Epstein Secrets

H A D D O N MORGAN FOREMAN Haddon, Morgan and Foreman, P C Jeffrey S. Paglluca August 9, 2020 VIA EMAIL Assistant United States Attorney The Silvio J. Mollo Building One Saint Andrew's Plaza New Y

disclosure of confidential material in v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) and a related appeal in the United States Court of Appeals for the Second Circuit, 20-2413. We intend to ask Judge Nathan for permission to refer to and attach, as exhibits, the above referenced discovery materials which relate t

rsuant to this Court's Order of March 29, 2021 (Dkt. No. 189). Regards, Nicole EFTA00103377 www.hmflaw.com Nicole Simmons Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 EFTA00103378

2021 (Objection to Proposed Redactions of Government's Omnibus Response & Exhibit 5) at 2-3 aemoir detailing her private family matters released by Second Circuit in The Billionaire Playboys Club manuscript). The government also persists in using pseudonyms in this case such as "Minor Victim 2" in place of an

Maxwell OPhintiff DDefendant ['Appellant/Petitioner nAppeUee/Respondent MOVING ATTORNEY: Ty Gee [name of attorney, with fm. Haddon, Morgan and Foreman, P.C. v. Maxwell OPPOSING PARTY: Plaintiff OPPOSING ATTORNEY: Paul Cassell address. phone number and e-mail) S.J. Quinney College of Law at the

hat the district court (or Ms. Maxwell or Ms. M) unjustifiably delayed public access to the summary judgment papers. This is incorrect. In Lugosch the Second Circuit was understandably impatient with the district court's delay in acting on two newspapers' motion to intervene to unseal the summary judgment filing

)-585-5202 Fax: (801)-585-2750 Email:[email protected] DEFENDANT ATTORNEY(S): Jeffrey S. Pagliuca [PRO HAC VICE;ATTORNEY TO] Haddon Morgan and Foreman 150 East 10th Avenue Denver, CO, USA 80203 (303)-831-7364 Fax: (303)-832-2628 Email:[email protected] Laura A. Menninger [ATTORNEY TO BE NOTIC

aneous: Respondent: Sharon Churcher; Jeffrey Epstein DOCKET CASE NUMBER: 1:15cv7433 OTHER DOCKET CASE NUMBER: 1:17mc00025 U.S. Court of Appeals, Second Circuit, 17-01625 FILING DATE: 9/21/2015 JURISDICTION: Diversity JUDGE: Robert W. Sweet NATURE OF SUIT: 320 Assault, Libel & Slander FILING TYPE: Civil

lease let us know if our proposal is agreeable to you and we can file it with the Court as unopposed. -Laura Laura A. Menninger Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 www.hmflaw.com CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or pr

r seal will be subject to a press request to unseal it, we need to ensure at the outset that we only mark things as confidential that the Court (and Second Circuit) will view as such when making an unsealing determination, so we included a definition of "Confidential" consistent with the case law. See, e.g., B

fully submitted, /s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) Ty Gee (pro hac vice) Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver. CO 80203 Phone: Fax: Attorneys for Ghislaine Maxwell 21 EFTA00074984 Ca a:Mag0743tikIcAlPneDbt0rfiefiFO72

rivacy interests of non- parties ... represents a legitimate basis for sealing judicial documents"). B. Effect of Previous Unsealing of Documents by Second Circuit Plaintiff claims that if a document is already public in another context, then it should be unsealed. She cites no law for this proposition, which

nt/Petkioner DAppellet/Respondent MOVING ATTORNEY: Adam Mueller [name of attorney, with fon, address, phone number and e-mail) Haddon, Morgan and Foreman, P.C. Boies Schiller & Flexner LLP OPPOSING ATTORNEY: Sigrid McCawley Court- Judge/ Agency appealed from: Hon. Loretta A. Preska, District Judge

rm T-I080 (rev.12-13) EFTA00074903 Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page2 of 38 20-2413 United States Court of Appeals for the Second Circuit —against — GHISLAINE MAXWELL, Plaintiff-Appellee, Defendant-Appellant, ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRIC

0 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon. Morgan and Foreman. PC Laura A. Menninger www hmacrw tom 2020 Order (Doc. 1096) v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: I write in respons

F APPEAL PLEASE TAKE NOTICE that Ghislaine Maxwell, Defendant in the above-captioned case, hereby appeals to the United States Court of Appeals for the Second Circuit from the district court's Order of July 23, 2020, unsealing the deposition materials and the Order of July 29, 2020, denying Ms. Maxwell's motion t

Haddon, Morgan and Foreman. P.c Jeffrey Paglluca II A D D O N M OR G A N FOREMAN 303.832.2628 August 24, 2020 VIA EMAIL The Honorable Alison J. Nathan United States Di

have been incorrect remains to be litigated; 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 informatio

oon of June 8, 1967. At 4:45 p. m. the jury returned to the courtroom and the following transpired: "THE COURT: I have this written note from the Foreman of the jury: 'Please reread the final instructions to the jury including a definition of terms, especially inducement and in- tent; also, the spec

. Nathan FLEISCHER, Petitioner, COMMISSIONER OF INTERNAL REV- ENUE, Respondent Nos. 219-220, Dockets 31638-91639. United States Court of Appeals Second Circuit. Argued April 9, 1968. Deckled Oct. 31, 1968. Proceedings on petition for review of decision and order of Tax Court that taxpayer's deductions f