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ial jurors, to incriminating evidence that the law has determined may not be used to support a conviction"), cited with approval in United States a Avenatti , (S1) 19 CR 373 PGG, 2020 WL 70952, at *3 (S.D.N.Y. Jan. 6, 2020). Based on these cases, the Court may make specific findings supporting the sealin
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
ngton Times <https://www.washingtontimes.com/news/2020/jul/29/michael-avenatti-provided- taxpayer-funded-lawyerk (7/29, Dinan, 492K) reports attorney Michael Avenatti, "who used to dominate cable news shows with his threats to take down President Trump, is now so poor that he was awarded a court- appointed lawyer
2015 civil lawsuit that included a deposition given by Maxwell in the case brought by Epstein accuser Virginia Giuffre. Less than three hours later, Preska denied it, citing `eleventh-hour request for reconsideration.' She allowed Maxwell's attorneys two days to seek a stay from an appeals court on two
llegations similar to those in the criminal case." Avenatti Cannot Afford To Pay Lawyer. The Washington Times (7/29, Dinan, 492K) reports attorney Michael Avenatti, "who used to dominate cable news shows with his threats to take down President Trump, is now so poor that he was awarded a court-appointed lawyer
015 civil lawsuit that included a deposition given by Maxwell in the case brought by Epstein accuser Virginia Giuffre. Less than three hours later, Preska denied it, citing `eleventh-hour request for reconsideration.' She allowed Maxwell's attorneys two days to seek a stay from an appeals court on two
llegations similar to those in the criminal case." Avenatti Cannot Afford To Pay Lawyer. The Washington Times (7/29, Dinan, 492K) reports attorney Michael Avenatti, "who used to dominate cable news shows with his threats to take down President Trump, is now so poor that he was awarded a court-appointed lawyer
015 civil lawsuit that included a deposition given by Maxwell in the case brought by Epstein accuser Virginia Giuffre. Less than three hours later, Preska denied it, citing `eleventh-hour request for reconsideration.' She allowed Maxwell's attorneys two days to seek a stay from an appeals court on two
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, P.0 Ty Gee 150 East
Page: EFTA00021861 →www.hmtlaw.com tgeefghmflaw.com Re: Reconsideration of the Court's July 23 Ruling Giuffre 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
Page: EFTA00021861 →al jurors, to incriminating evidence that the law has determined may not be used to support a conviction"), cited with approval in United States v. Avenatti , (S1) 19 CR 373 PGG, 2020 WL 70952, at *3 (S.D.N.Y. Jan. 6, 2020). Based on these cases, the Court may make specific findings supporting the sealin
Page: EFTA00021867 →Entities connected to both Michael Avenatti and Loretta A. Preska

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
David Boies
PERSON
Julie K. Brown
PERSON
Donald Trump
PERSON
Michael Cohen
PERSON
Virginia Giuffre
PERSON
George W. Bush
PERSON
Bloomberg L.P.
ORGANIZATION
Colorado
LOCATIONSigrid McCawley
PERSON
Stephen Hawking
PERSONthe Southern District
LOCATIONSecond Circuit
ORGANIZATION
Department of Justice
ORGANIZATION
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Southern District of New York
ORGANIZATION