Epstein Secrets

fidential" designation of the Unsealing Materials is appropriate because they pertain to an ongoing grand jury investigation and because Chief Judge Colleen McMahon and Magistrate Judge Sarah Netburn have ordered that the Unsealing Materials remain under seal. The only exceptions to those sealing orders are the

ave ordered that the Unsealing Materials remain under seal. The only exceptions to those sealing orders are the permission contained in Chief Judge McMahon's April 9, 2019 Order (Bates Nos. SDNY_GM_00000904 through SDNY_GM_ 00000905), namely that the Order itself may be provided to Boies Schiller & Flex

ur baseless accusations of malfeasance in the civil litigation—accusations you now know to be false. Moreover, the Protective Order issued by Judge Alison J. Nathan in the above-referenced criminal case expressly provides that any and all discovery material produced to the defendant by the Government, regardles

overnment's proposed redactions on pages 1-128 all relate to materially inaccurate statements made by a prosecutor for the government to Chief Judge McMahon. They also relate to a sealed proceeding in which the government circumvented decades-old precedent in this Circuit which held that civil litigatio

H A D D O N MORGAN FOREMAN March 9, 2021 The Hon. Alison J. Nathan United States District Court Judge Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, r c Laura A. M

Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Objection to Proposed Redactions of Government's Omnibus Response & Exhibit 5 Dear Judge Nathan: On behalf of defendant Ghislaine Maxwell, we respectfully oppose certain of the redactions proposed by the government to their Omnibus Memorandum

l matter. If the former, the Government maintains that the "Confidential" designation of the Unsealing Materials is appropriate because Chief Judge Colleen McMahon and Magistrate Judge Sarah Netbum have ordered that the Unsealing Materials remain under seal. The only exceptions to those sealing orders are the

h Netbum have ordered that the Unsealing Materials remain under seal. The only exceptions to those sealing orders are the production of Chief Judge McMahon's April 9, 2019 Order (Bates Nos. SDNY_GM_00000904 through SDNY_GM_00000905) to Boies Schiller & Flexner LLP, and production of the entirety of the

investigation, and their public disclosure at this stage risks interference with that investigation. Moreover, the Protective Order issued by Judge Alison J. Nathan in the above-referenced criminal case expressly provides that any and all discovery material produced to the defendant by the Government, regardless

age was caused by the conditions in MDC and not by her. This was recently corroborated by another MDC inmate, Tiffany Days, who explained to Judge McMahon the sorts of conditions that are present at MDC: "I also survived the disgusting feces flood that we were 6 EFTA00089458 actually told to clean

died on BOP's watch and it is going to treat Ms. Maxwell as though she is Epstein. In sentencing another woman who was held at MDC, District Judge Colleen McMahon said the defendant "shouldn't have to suffer for the incompetence of the United States Department of Justice and its subsidiary agency, the Bureau

orney, with firm address, phone number and e-mail] United States Attorney's Office, So. Dist. of NY a_ nowise Court- Judge/ Agency appealed from: Alison J. Nathan, Southern District of New York Please check appropriate boxes: Has movant notifiedr posing counsel (required by Local Rule 27.1): DYes (explaii):

age was caused by the conditions in MDC and not by her. This was recently corroborated by another MDC inmate, Tiffany Days, who explained to Judge McMahon the sorts of conditions that are present at MDC: "I also survived the disgusting feces flood that we were 6 EFTA00096526 Case 21-58. Document 89

died on BOP's watch and it is going to treat Ms. Maxwell as though she is Epstein. In sentencing another woman who was held at MDC, District Judge Colleen McMahon said the defendant "shouldn't have to suffer for the incompetence of the United States Department of Justice and its subsidiary agency, the Bureau

. Dist. of NY 40 NW Third Street, PH 1, Miami, Florida 33128 One Saint Andrew's Plaza, New York, New York 10007 Court- Judge/ Agency appeakd from: Alison J. Nathan, Southern District of New York Please check appropriate boxes: Has movant notifiedr Aposing counsel (required by Local Rule 27.1): DYes L_No (expl

ession Hearing (USANYS) < Per our discussion, I am attaching: (1) Maxwell's two briefs raising the suppression argument; (2) the transcript of the McMahon proceedings and her opinion (Ex D, E, G); (3) our brief (see pp 59-115); and (4) the exhibits we attached to our motion (Ex 4-7). Judge Nathan has s

the McMahon proceedings and her opinion (Ex D, E, G); (3) our brief (see pp 59-115); and (4) the exhibits we attached to our motion (Ex 4-7). Judge Nathan has said that she will resolve the suppression motions "at a later time" ahead of trial. Thanks very much. From: (USANYS) < Sent: Tuesday, June 1

ng (USANYS) < (USANYS) < Per our discussion, I am attaching: (1) Maxwell's two briefs raising the suppression argument; (2) the transcript of the McMahon proceedings and her opinion (Ex D, E, G); (3) our brief (see pp 59-115); and (4) the exhibits we attached to our motion (Ex 4-7). Judge Nathan has s

the McMahon proceedings and her opinion (Ex D, E, G); (3) our brief (see pp 59-115); and (4) the exhibits we attached to our motion (Ex 4-7). Judge Nathan has said that she will resolve the suppression motions "at a later time" ahead of trial. Thanks very much. From: (USANYS) < Sent: Tuesday, June 1

ng (USANYS) < (USANYS) < Per our discussion, I am attaching: (1) Maxwell's two briefs raising the suppression argument; (2) the transcript of the McMahon proceedings and her opinion (Ex D, E, G); (3) our brief (see pp 59-115); and (4) the exhibits we attached to our motion (Ex 4-7). Judge Nathan has s

the McMahon proceedings and her opinion (Ex D, E, G); (3) our brief (see pp 59-115); and (4) the exhibits we attached to our motion (Ex 4-7). Judge Nathan has said that she will resolve the suppression motions "at a later time" ahead of trial. Thanks very much. From: (USANYS) Sent: Tuesday, June 15,

inal) (quoting Mincey v. Arizona, 437 U.S. 385, 398 (1978)). Here, the government violated due process when it misrepresented and misled Chief Judge McMahon in an ex pane proceeding to circumvent the civil protective order, and it independently would violate due process for the government to be allowed

Case 1:20-cr-00330-AJN Document 234 Filed 04/22/21 Page 1 of 5 HADDON MORGAN FOREMAN April 22, 2021 The Hon. Alison J. Nathan United States District Court Judge Southern District of New York 40 Foley Square New York, NY 10007 Haddon, Morgan and Foreman, P.0 Jeffrey S.

H A D D O N MORGAN FOREMAN August 17, 2020 VIA EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: Request to Modify Protective Order (UNDER SEA

.c Jeffrey Paglloca 150 East 10th Avenue Denver, Colorado 80203 rti 303.831.7364 FX 303.832.2628 www.hmflaw.com jpaglucaahmflaw.com Dear Judge Nathan, Defendant Ghislaine Maxwell, pursuant to paragraph 18 of this Court's Protective Order (Doc. # 36), requests that the Court enter an Order allowin

s deposition on July 23 and denied Ms. Maxwell's motion to reconsider on July 30, she apparently did not know that, as described below, Chief Judge McMahon had already granted an ex pane request from the government to obtain Ms. Maxwell's deposition (among thousands of other confidential and sealed mate