Epstein Secrets

15-cv-07433-LAP Ms. Maxwell's Objections to Unsealing Docket Entries 143. 173. and 199 and to Unsealing Docket Entries 164 and 230 at This Time. Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 EFTA00075004 CageaUlg0caAIDer0dthhilfii igl5

e. The absence of a response, however, does not end the analysis. Although the Court's Protocol requires consideration of objections from the other Non-Parties yet to be noticed, the Court could (and should) determine, based on the circumstances of the Sealed Materials selected here, that the items are appr

to place Plaintiff's submission into context. DE 153 is Plaintiff's reply which, again quotes from Ms. Maxwell's deposition and references numerous Non-Parties. DE 153-1 contains 7 exhibits. Exhibit I is a portion of Ms. Maxwell's deposition. Exhibit 2 contains a "Flight Log Summary Chart" prepared by Plain

deposition materials and the Order of July 29, 2020, denying Ms. Maxwell's motion to reconsider. Dated: July 29, 2020. Respectfully submitted, s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) Ty Gee (pro hac vice) HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Ghislaine Max

week per Non-Party to agree to the excerpts to send to them for review. But on balance we agree that having a sense of the number of participating Non-Parties will aid the Court in conducting future proceedings, we have agreed to Plaintiff's suggestion on that front. The parties can submit a proposed modif

500 Pearl Street New York, NY 10007 Re: 3, 2020 Order (Doc. 1096) v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Haddon, Morgan and foreman, P C Laura A. Menninger 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 EX 303.832.2628 www.hmtlaw.com LMenningergthrntlaw.com Dear Judge Preska: I write

week per Non-Party to agree to the excerpts to send to them for review. But on balance we agree that having a sense of the number of participating Non-Parties will aid the Court in conducting future proceedings, we have agreed to Plaintiff's suggestion on that front. The parties can submit a proposed modif

earl Street New York, NY 10007 Re: August 3, 2020 Order (Doc. 1096) v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Haddon, Morgan and Foreman, P.0 Laura A. Menninger 150 East 10th Avenue Denver, Colorado 80203 Pll 303.831.7364 EX 303.832.2628 www.hmtlaw.com LMenninger4hrntlaw.com Dear Judge Preska: I write

week per Non-Party to agree to the excerpts to send to them for review. But on balance we agree that having a sense of the number of participating Non-Parties will aid the Court in conducting future proceedings, we have agreed to Plaintiff's suggestion on that front. The parties can submit a proposed modif