Epstein Secrets

i Herald Media Company's (collectively, "Miami Herald") moved to make available to the public all sealed and redacted court filings. District Judge Sweet held a hearing in May 2018, and denied the motion in August 2018. In its appellate briefs the Herald did not argue the district court misconstrued

ated. 25 EFTA00791894 Case 18-2868, Document 141, 03/15/2019, 2519388, Page27 of 27 Respectfully submitted, s/ Ty Gee Ty Gee Laura Menninger Adam Mueller HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 Tel 303.831.7364 [email protected]; [email protected]; [email protected]

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

-Appellant Ghislaine Maxwell OPPOSING PARTY: Plaintiff-Appellee 9PlaintifT attendant EiAppellant/Petkioner DAppellet/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: S

ons took place only after everyone agreed on the record that the testimony would be confidential and sealed pursuant to the Protective Order. Judge Sweet made factual findings on exactly this point, which this Court never questioned in Brown.M325 F. Supp. 3d at 445, 446 (recognizing that Ms. Maxwell

ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, 15-CV-7433 (LAP) Ghislaine Maxwell's Opening Brief Ty Gee Adam Mueller HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Den r 2 Tel. Attorneys for Defendant-Appellant Ghislaine Maxwell EFTA00075477 Case 20-24

ant to the Court's exercise of its inherent supervisory powers. The documents at issue here relate to discovery motions previously decided by Judge Sweet, and so the Court SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00076444 Case 20-2413, Document 44, 08/20/2020, 2913556, Page63 of 78 3

D STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, 15-CV-7433 (LAP) APPENDIX Volume IV of VIII (Pages App.-0777 to App.-0852) Ty Gee Adam Mueller HADDON, MORGAN AND FOREMAN, P.C. Attorneys or e en ant-Appellant Ghislaine Maxwell EFTA00076383 Case 20-2413, Document 44, 08/20/2020, 2913556, Pa

a settlement agreement, and the case was closed the next day. C. Motions to Intervene and Unseal Over the course of the litigation before Judge Sweet, three outside parties attempted to unseal some or all of the sealed material. On August 11, 2016, Dershowitz moved to intervene, seeking to unsea

ine J. Harrington, New York, NY, on the brief), Holland & Knight LLP, Miami, FL, for Intervenors-Appellants Julie Brown and Miami Herald. Ty Gee (Adam Mueller, on the brief), Haddon, Morgan and Foreman, P.C., Denver, CO, for Defendant-Appellee Ghislaine Maxwell. Paul G. Cassell (Sigrid S. McCawley,

ed a settlement agreement, and the case was closed the next day. C. Motions to Intervene and Unseal Over the course of the litigation before Judge Sweet, three outside parties attempted to unseal some or all of the sealed material. On August 11, 2016 Dershowitz moved to intervene, seeking to unseal

ine J. Harrington, New York, NY, on the brief), Holland & Knight LLP, Miami, FL, for Intervenors-Appellants Julie Brown and Miami Herald. TY GEE (Adam Mueller, on the brief), Haddon, Morgan and Foreman, P.C., Denver, CO, for Defendant-Appellee Ghislaine Maxwell. 3 EFTA00092310 PAUL G. CASSELL (Sigrid