Epstein Secrets

Case 21-58. Document 89-1, 05/17/2021, 3102450, Pagel of 14 UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT Thurgood Marshall U.S. Courthouse 40 Foley Square, New York, NY 10007 Telephone: 212-85

ARKUS/MOSS PLLC 40 N.W. Third Street, PH 1 Miami, Florida 33128 Tel markuslaw.com EFTA00096520 Case 21-58. Document 89-1, 05/17/2021, 3102450, Page3 of 14 Appellant Ghislaine Maxwell's Renewed Motion for Bond Although this Court denied Ghislaine Maxwell's motion for bond (see Ex. A, Order, Apri

17/2021 Service by: DCM/ECF DOther [Attach proof of service] Form T-1080 (rev.I2-13) EFTA00096519 Case 21-58. Document 89-1, 05/17/2021, 3102450, Paget of 14 No. 21-770 & 21-58 In the Malta *tates Court of Appeat5 for the *tomb Circuit UNITED STATES OF AMERICA, Appellee, v. GHISLAINE MAXWELL,

t comes up from the drain in her unit; (5) can't keep the guards from seizing and 2 EFTA00096522 Case 21-58. Document 89-1, 05/17/2021, 3102450, Page5 of 14 going through her attorney-client materials; and (6) can't search, print, highlight, or sort the discovery because the "computer" she was giv

he government contradicts a previous report that Ms. Maxwell "has an eye mask." This allegation, immediately refuted by her counsel, was a focus of the Second Circuit's questioning during oral argument of Ms. Maxwell's bail appeal. Now, the government reports that the MDC cannot provide an eye mask to Ms. Maxwell a

Case 18-2868, Document 141, 03/15/2019, 2519388, Pagel of 27 UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT Thurgood Marshall U.S. Courthouse 40 Foley Square, New York, NY 10007 Telephone: 212-85

rials, and (2) to hold in abeyance the Orders until the disposition of this Motion. EFTA00791870 Case 18-2868, Document 141, 03/15/2019, 2519388, Page3 of 27 Introduction The panel's Order to Show Cause and March 13 Order directing the appellees to produce the sealed and redacted summary judgment

e sealed and redacted information, not only will she be able to continue pursuing 3 EFTA00791872 Case 18-2868, Document 141, 03/15/2019, 2519388, Page5 of 27 publicity for profit, but also she will be able to engage in the prurient trafficking of others' private, personal and confidential informati

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

Case 20-2413, Document 44, 08/20/2020, 2913556, Pagel of 78 20-2413 United States Court of Appeals for the Second Circuit —against— GHISLAINE MAXWELL, SHARON CHURCHER, JEFFREY EPSTEIN, PlaintiffiAp

HADDON, MORGAN AND FOREMAN, P.C. Attorneys or e en ant-Appellant Ghislaine Maxwell EFTA00076383 Case 20-2413, Document 44, 08/20/2020, 2913556, Paget of 78 Docket Entries App.-0001 Order regarding Ms. Maxwell's Letter Motion to Reconsider July 23, 2020 Ruling, Dated July 29, 2020 (Dkt. 1079) A

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