Epstein Secrets

or good cause shown following notice to all parties and an opportunity for them to be heard. 13Y THE STATES DISTRICT JUDGE 6 EFTA00793046 To: Laura Menninger, Esq. Re: Giuffre v. Maxwell, Case No. 1S-cv-07433 United States District Court For the Southern District of New York March 17, 2016 Protective O

that case.' Under the terms of the Protective Order, "Confidential" documents "shall not be disclosed or used for any purpose except the A copy of the Protective Order is attached hereto as Exhibit A. Out of respect for the provisions of the Protective Order, we are submitting this letter under seal. EFTA00793037

udge Marra /172 Proposed Redactions: Statement of Undisputed Facts 11- 17 and 35-52 10 EFTA00794224 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];

c disclosure of any sealed or redacted summary judgment materials. The OTSC is, however, incomplete because the dozens of individuals who relied on the Protective Order had no notice of the Order and have had no opportunity to respond. We interpose the following general objections: 1. All sealed and redacted summa

, By: Paul G. Cassell, Esq. Counsel for Defendant Ghislaine Maxwell: HADDON, MORGAN AND FOREMAN, P.C., 150 East 10th Avenue, Denver, CO 80203, By: Laura A. Menninger, Esq., Jeffrey S. Pagliuca, Esq., Ty Gee, Esq. Counsel for Intervenor Michael Cemovich: RANDAZZA LEGAL GROUP, PLLC, 100 Pearl Street, 14th Floor,

mmon law right of access, or of the more robust First Amendment right to access certain judicial documents. Id. at 119-20. It is a given accepted by the Protective Order that the trial and all trial documents are accessible and public absent special circumstances. *8 1121 II3IUnder the common law approach, once a do