Epstein Secrets

was balanced against "the duty of the courts," id. at 602, including the duty to ensure fairness to the defendants, see id. at 602 n.14. In In re New York Times Co., 828 F.2d 110 (2d Cir. 1987), cited with approval in United States v. Longueuil, 567 Fed. App'x 13, 16 (2d Cir. 2014), Judge Weinstein denied the me

www.hmllaw.com [email protected] Re: Reconsideration of the Court's July 23 Ruling Giuffie v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its Protective Order and punish its violation. Ms. Maxwell's two depositio

Ces2e.29-12,407413r3cliAlienDtidutinEl t310282 if663615/233/2174ig Plage aoat 9 HADDON MORGAN FOREMAN July 29, 2020 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, P C Ty Gee 150 East

st, 677 F.2d 230 (2d Cir. 1982) 25 v. Maxwell, 325 F. Supp. 3d 428 (S.D.N.Y. 2018) 6, 25, 40 In re Mazzeo, 167 F.3d 139 (2d Cir. 1999) 17 In re New York Times Co., 828 F.2d 110 (2d Cir. 1987) 37, 40 In re Teligent, Inc., 640 F.3d 53 (2d Cir. 2011) 1 Joy v. North, 692 F.2d 880 (2d Cir. 1982) 22 Louis Vuitt

order unsealing the deposition material, including Ms. Maxwell's April 2016 deposition transcript. On July 23, over Ms. Maxwell's objection, Judge Preska —who is presiding over the civil case and the litigation about the unsealing of the district court filings —ordered the complete unsealing of Ms. M

CM/ECF, which will send notification of the filing to all counsel of record. I also certify that I mailed a copy of the opening brief to: The Hon. Loretta A. Preska District Judge United States District Court for the Southern District of New York (via United States mail) s/ Nicole Simmons 43 EFTA00075525

y was balanced against "the duty of the courts," id. at 602, including the duty to ensure fairness to the defendants, see W. at 602 n.14. In In re New York Times Co., 828 F.2d 110 (2d Cir. 1987), cited with approval in United States v. Longueuil, 567 Fed. App'x 13,16 (2d Cir. 2014), Judge Weinstein denied the med

Case 1:15-cv-07433-LAP Document 1078 Filed 07/29/20 Page 1 of 9 HADDON MORGAN FOREMAN July 29, 2020 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, r.0 Ty Gee 150 East

www.hmtlaw.com [email protected] Re: Reconsideration of the Court's July 23 Ruling Giuffie v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its Protective Order and punish its violation. Ms. Maxwell's two depositio

s at publication, defined as the earliest date on which the work was placed on sale or became generally available to the public.' " Van Buskirk v. The New York Times Co. 325 F.3d 87, 89 (2d Cir. 2003) (Quoting Tomasino v. William Morrow & Co. 174 A.D.2d 734, 571 N.Y.S.2d 571, 572 (2d Dep't 1991)). Dershowitz invoke

ing that she was forced to engage in sexual activity with him. Defendant moved to dismiss and to disqualify law firm Holdings: The District Court, Loretta A. Preska, Senior District Judge, held that: III single publication rule did not apply to bar claim on limitations grounds; (2) plaintiffs allegations were

dia L. Rep. 1721 (E.D. Tenn. 2008) 5 Medina v. United Christian Evangelistic Ass'n No. 08-22111-CIV, 2009 WL 5066675 (S.D. Fla. Dec. 15. 2009) 6 New York Times Co. v. Gonzales, 459 F.3d 160 (2d Cir. 2006) 2 Nicholas v. Poughkeepsie Say. Bank/FSB, No. 90 Civ. 1607 (RWS), 1991 WL 113279 (S.D.N.Y. June 14, 1991

g Petroleum Products standard to confidential materials): E Gallo Winery v. Encana Energy Servs.. Inc.. 33 Media L. Rep. 1413. 1414 (S.D.N.Y. 2005) (Preska, J.) (applying petroleum Products standard to both confidential sources and confidential materials) (copy annexed as Ex. A to Carroll Reply Decl.);

dia L. Rep. 1721 (E.D. Tenn. 2008) 5 Medina v. United Christian Evangelistic Ass'n No. 08-22111-CIV, 2009 WL 5066675 (S.D. Fla. Dec. 15. 2009) 6 New York Times Co. v. Gonzales, 459 F.3d 160 (2d Cir. 2006) 2 Nicholas v. Poughkeepsie Say. Bank/FSB, No. 90 Civ. 1607 (RWS), 1991 WL 113279 (S.D.N.Y. June 14, 1991

g Petroleum Products standard to confidential materials): E Gallo Winery v. Encana Energy Servs.. Inc.. 33 Media L. Rep. 1413. 1414 (S.D.N.Y. 2005) (Preska, J.) (applying petroleum Products standard to both confidential sources and confidential materials) (copy annexed as Ex. A to Carroll Reply Decl.);

7) 13 Hunt v. Enzo Biochem, Inc., 904 F. Supp. 2d 337 (S.D.N.Y. 2012) 12 In re Long Island Lighting Co., 129 F.3d 268 (2d Cir. 1997) 15 In re New York Times Co., 828 F.2d 110 (2d Cir. 1987) 20 In re Sims v. Blot, 534 F.3d 117 (2d Cir. 2008) 14 In re Teligent, Inc., 640 F.3d 53 (2d Cir. 2011) 9 In re

-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 (S.D.N.Y.) Please check appropriate boxes: Has movant notifiedr oposing counsel (required by Local Rule 27.1): lElYes I [No (expla