Epstein Secrets

is name. Intervenor's appeal of this Court's order denying his motion, inter alia, to unseal materials filed in this case is slated for argument in the Second Circuit Court of Appeals in February 2019. In recent days, the Miami Herald and other media outlets — prompted, we believe, by Ms. Roberts and/or her representatives — have

A L. CiRE.ENBERGER ZOE SALZMAN SAM SHAPIRO By ECF EMERY CELLI BRINCICERHOFF & ABADY LLP Honorable Robert W. Sweet United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 ATTORNEYS AT LAW 600 FIFTH AVENUE. AT ROCKEFF.U.F.R a:Nita 10^, FLOOR NEW YORK, NEW YORK 10020

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

Paglluca II A D D O N M OR G A N FOREMAN 303.832.2628 August 24, 2020 VIA EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York Re: Reply in Support of Request to Modify Protective Order (Under Seal)i United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judg

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

H A D D O N MORGAN FOREMAN May 12, 2021 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Haddon, Morgan and Foreman. t.c Jeffrey PaglIuca 150 East 10th Avenue Denver. Colorado 80203 PH