Epstein Secrets

The Hon. Alison J. Nathan United States District Court Judge Southern District of New York 40 Foley Square New York, NY 10007 Haddon, Morgan and Foreman, P.0 Jeffrey S. PagRoca Denver, Colorado 80203 wv.rw.nmnaw.com Re: United States v. Ghisiaine Maxwell, 20 Cr. 330 (AJN) Response to Dkt. No. 227

. at I. That's because Ms. Maxwell's motions to suppress allege violations of the due process clause, the Fourth Amendment, the Fifth Amendment, and the Second Circuit's decision in Manindell v. International Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979). If this Court agrees with Ms. Maxwell's arguments, not only

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

at the district court (or the appellees) unjustifiably delayed resolution of the unseal motions and its abuse of discretion in failing to adhere to the Second Circuit's "clear[]"3 precedent. We respectfully submit that neither conclusion warrants the extraordinary action being contemplated by the panel. A. The dist

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

re "unjustified obstacles" or that the public will never have access to these documents -- reflect unjustified criticisms of the Protocol itself and the Second Circuit's decision in Brown, both of which fairly outline the legal process for parties and Non-Parties alike to be heard with respect to unsealing. Notably,

fully submitted, /s/Jeffrey S. Pagliuca 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 1 EFTA00075005 CagealAgOat#714k0EAFierbdathiAlioRP2PilaWfittleagetticjit Pit 3 CERTIFICATE OF SERV

19) (emphasis supplied; footnote omitted; quoting United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995) ("Amodeo r')). Amodeo I, the inception of the Second Circuit's principle that a file stamp is not a judicial-document talisman, is instructive. There an appointed Court Officer tasked parties; DE 204-1 referenc

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

Cr. 330 (AJN) (the "Criminal Action"). The information implicates Ms. Maxwell's right to due process and fairness in this civil action and affects the Second Circuit's review of the Court's unsealing order of July 23, 2020. Additionally, the information implicates her rights as a criminal defendant guaranteed unde

ning. Who is on for Ms. Maxwell, please? MS. MENNINGER: Good morning, your Honor, Laura Menninger on behalf of Ms. Maxwell from Haddon Morgan and Foreman. THE COURT: Good morning. Counsel, as you know, today the Court announces its rulings on the unsealing of the motions associated with docket entr

Messages involving the defendant. Portions of this document were redacted and released by the Second Circuit. So whatever happened with respect to the Second Circuit's release, we will abide by its ruling. 339. Response in opposition to the motion to compel. Unseal and redact the names, identifying information, a

ew York 500 Pearl Street New York, NY 10007 Re: August 3, 2020 Order (Doc. 1096) v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Haddon, Morgan and Foreman, P.0 Laura A. Menninger 150 East 10th Avenue Denver, Colorado 80203 Pll 303.831.7364 EX 303.832.2628 www.hmtlaw.com LMenninger4hrntlaw.com Dea

0 Cr. 330 (MN) (the "Criminal Action"). The information implicates Ms. Maxwell's right to due process and fairness in this civil action and affects the Second Circuit's review of the Court's unsealing order of July 23, 2020. Additionally, the information implicates her rights as a criminal defendant guaranteed unde