Epstein Secrets

H A D D O N MORGAN FOREMAN August 17, 2020 VIA EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: Request to Modify Protective Order (UNDER SEA

.c Jeffrey Paglloca 150 East 10th Avenue Denver, Colorado 80203 rti 303.831.7364 FX 303.832.2628 www.hmflaw.com jpaglucaahmflaw.com Dear Judge Nathan, Defendant Ghislaine Maxwell, pursuant to paragraph 18 of this Court's Protective Order (Doc. # 36), requests that the Court enter an Order allowin

The district court denied the motion to unseal. The Miami Herald appealed on September 28, 2018. On July 3, 2019 the Second Circuit reversed Judge Sweet's ruling. Brown v. Maxwell, 929 F.3d 41, 44-45 (2d Cir. 2019). Upon the issuance of the mandate, on August 9, 2019, it largely unsealed the summary

021 10:40 AM To: (USANYS) Cc: (USANYS) ‹ > Subject: RE: Question re A1N/Maxwell Suppression Hearing Can I see our original application to Judge Sweet? And I assume there was no transcript before Judge S? EFTA00015277 --- PAGE BREAK --- From: (USANYS) Sent: Tuesday, June 15, 2021 5:45 PM To:

the McMahon proceedings and her opinion (Ex D, E, G); (3) our brief (see pp 59-115); and (4) the exhibits we attached to our motion (Ex 4-7). Judge Nathan has said that she will resolve the suppression motions "at a later time" ahead of trial. Thanks very much. From: (USANYS) Sent: Tuesday, June 15,

r potential witnesses that going forward it will not hesitate to take appropriate action in the face of violations of any relevant rules." Id. judge Nathan said she would ensure "strict compliance" with the rules and "ensure that the Defendant's right to a fair trial will be safeguarded." Id. On July

n part, Ms. Maxwell needed information concerning any such investigation to assess "the impact on any 5th Amendment privilege." ki. at 2, 4-5. 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

6, 2021 10:40 AM To: (USANYS) Cc: (USANYS) Subject: RE: Question re AJN/Maxwell Suppression Hearing Can I see our original application to Judge Sweet? And I assume there was no transcript before Judge S? From: (USANYS) Sent: Tuesday, June 15, 2021 5:45 PM To: (USANYS) < Cc: I (USANYS) Subje

the McMahon proceedings and her opinion (Ex D, E, G); (3) our brief (see pp 59-115); and (4) the exhibits we attached to our motion (Ex 4-7). Judge Nathan has said that she will resolve the suppression motions "at a later time" ahead of trial. Thanks very much. From: (USANYS) < Sent: Tuesday, June 1

021 10:40 AM To: (USANYS) Cc: (USANYS) <a> Subject: RE: Question re A1N/Maxwell Suppression Hearing Can I see our original application to Judge Sweet? And I assume there was no transcript before Judge S? From: (USANYS) Sent: Tuesday, June 15, 2021 5:45 PM To: (USANYS) < Cc: (USANYS) (USANYS

the McMahon proceedings and her opinion (Ex D, E, G); (3) our brief (see pp 59-115); and (4) the exhibits we attached to our motion (Ex 4-7). Judge Nathan has said that she will resolve the suppression motions "at a later time" ahead of trial. Thanks very much. From: (USANYS) < Sent: Tuesday, June 1