Epstein Secrets

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

Third, to prevent against some of the errors that occurred during the last round of unsealings, we request that the Protocol be amended to require the Responding Original Party who proposes unsealing to supply with their Response a proposed unredacted set of the pleadings at issue, for the Court's consideration and for the

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

Third, to prevent against some of the errors that occurred during the last round of unsealings, we request that the Protocol be amended to require the Responding Original Party who proposes unsealing to supply with their Response a proposed unredacted set of the pleadings at issue, for the Court's consideration and for the

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

Third, to prevent against some of the errors that occurred during the last round of unsealings, we request that the Protocol be amended to require the Responding Original Party who proposes unsealing to supply with their Response a proposed unredacted set of the pleadings at issue, for the Court's consideration and for the