Epstein Secrets

cute this action. The government has not articulated a cogent reason for that information to be kept from the other judicial officers. Sincerely, Jeffrey S. Pagliuca CC: Counsel of Record (via ECF) EFTA00088210

other judicial officers. Sincerely, Jeffrey S. Pagliuca CC: Counsel of Record (via ECF) EFTA00088210

ne Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, Defendant Ghislaine Maxwell filed a simple request: that she be permitted to disclose under seal to the Second Circuit Court of Appeals and a separate district court in this same court (the "Civil Litigation") the fact that her adversary in the civil case pending in those two fora al

to address any questions regarding relevance and admissibility ex-parte should the Court need any additional information. Respectfully Submitted, Jeffrey S. Pagliuca CC: Counsel of Record (via ECF) EFTA00096517

Y 10007 Haddon, Morgan and Foreman. t.c Jeffrey PaglIuca 150 East 10th Avenue Denver. Colorado 80203 PH

and relies on lawyers adverse to Ms. Maxwell for cover. This type of selective disclosure of information is routinely rejected by courts, including the Second Circuit Court of Appeals. Known as the "fairness doctrine," when one party makes assertions about parts of a communication or writing the entire communication loses protecte

and relies on lawyers adverse to Ms. Maxwell for cover. This type of selective disclosure of information is routinely rejected by courts, including the Second Circuit Court of Appeals. Known as the "fairness doctrine," when one party makes assertions about parts of a communication or writing the entire communication loses protecte

ddress any questions regarding relevance and admissibility ex-parte should the Court need any additional information. Respectfully Submitted, g's Jeffrey S. Pagliuca CC: Counsel of Record (via ECF) EFTA00014678