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York United States Courthouse New York, New York 10007 Re: In re Application to Unseal Civil Discovery Materials, USAO No. 2018R01618 Dear Judge Sweet: The Government writes respectfully in connection with its sealed application and proposed order pursuant to the All Writs Act, Title 28, United St
er pursuant to the All Writs Act, Title 28, United States Code, Section 1651, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP (the "A in connection with the matter v. Ghislaine Maxwell, et al. ("M"), 15 Civ. 7433 (RWS) (the "Litigation"), a copy of which is enclosed as
8. In part, Ms. Maxwell needed information concerning any such investigation to assess "the impact on any 5th Amendment privilege." Id. at 8. Judge Sweet denied that motion. The day before Ms. Maxwell's deposition, the Court ordered that "[a]ny materials that the plaintiff has with respect to any cri
Appellet/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 (S.D.N.Y.) Please check appropriate
York United States Courthouse New York, New York 10007 Re: In re Application to Unseal Civil Discovery Materials, USAO No. 2018R01618 Dear Judge Sweet: The Government writes respectfully in connection with its sealed application and proposed order pursuant to the All Writs Act, Title 28, United St
er pursuant to the All Writs Act, Title 28, United States Code, Section 1651, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP the "A in connection with the matter v. Ghislaine Maxwell, et al. (a), (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A. Back
y 29, 2016 Meeting Exhibit 6: November 30, 2018 Email Exhibit 7: December 6, 2018 Email Exhibit 8: February 28, 2019 Government Letter to Judge Sweet Exhibit 9: February 28, 2019 Government Letter to Judge Netburn Exhibit 10: Transcript of April 22, 2016 Deposition Exhibit 11: Transcript of Jul
on to the public, as part of an ongoing campaign to vilify Ms. Maxwell." (Def. Mot. 7 at 16). She again cites the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obtain materials from the Giuffre civil litigation. (Id.). Leaving aside the fact that, as set forth in Section IV, the Gover
y 29, 2016 Meeting Exhibit 6: November 30, 2018 Email Exhibit 7: December 6, 2018 Email Exhibit 8: February 28, 2019 Government Letter to Judge Sweet Exhibit 9: February 28, 2019 Government Letter to Judge Netburn Exhibit 10: Transcript of April 22, 2016 Deposition Exhibit 11: Transcript of Jul
on to the public, as part of an ongoing campaign to vilify Ms. Maxwell." (Def. Mot. 7 at 16). She again cites the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obtain materials from the Giuffre civil litigation. (Id.). Leaving aside the fact that, as set forth in Section IV, the Gover
y 29, 2016 Meeting Exhibit 6: November 30, 2018 Email Exhibit 7: December 6, 2018 Email Exhibit 8: February 28, 2019 Government Letter to Judge Sweet Exhibit 9: February 28, 2019 Government Letter to Judge Netbum Exhibit 10: Transcript of April 22, 2016 Deposition Exhibit 11: Transcript of July
on to the public, as part of an ongoing campaign to vilify Ms. Maxwell." (Def. Mot. 7 at 16). She again cites the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obtain materials from the civil litigation. (Id.). Leaving aside the fact that, as set forth in Section IV, the Government o
ents that were placed under seal and included in protective order. Holdings: The United States District Court for the Southern District of New York, Sweet, J., held that: m news media and journalist could intervene in action; 121 public did not have right of access, either under First Amendment or co
Page: EFTA00020541 →pany: HOLLAND & KNIGHT LLP, 31 West 52nd Street, New York, NY 10019, By: Christine N. Walz, Esq., Sanford L. Bohrer, Esq. Counsel for Plaintiff : BOIES SCHILLER & FLEXNER LLP, 401 E. Las Olas Boulevard, Suite 1200, Fort Lauderdale, FL 33301, By: Sigrid S. McCawley, Esq., Meredith L. Schultz, Esq., BOIES SCHILLER & FLEXNE
Page: EFTA00020552 →Entities connected to both Sweet and Boies Schiller & Flexner LLP

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
David Boies
PERSON
Virginia Giuffre
PERSONSigrid McCawley
PERSON
Bradley Edwards
PERSON
Julie K. Brown
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
United States
LOCATIONJane Doe
PERSON
Alan Dershowitz
PERSONJeffrey Pagliuca
PERSON
Colorado
LOCATIONthe Southern District
LOCATIONMartindell
PERSONEmmy Taylor
PERSON
Denver
LOCATIONSouthern District
LOCATION
Southern District of New York
ORGANIZATION