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

of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New lark 10007 August 12, 2020 VIA EMAIL Jeffrey S. Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, CO 80203 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Mr. Pagliuca: The Government writes i

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

of New York The Silvio J. Motto Building One Saint Andrew's Plaza New York. New York 10007 August 12, 2020 VIA EMAIL Jeffrey S. Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, CO 80203 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Mr. Pagliuca: The Government writes i

ork 40 Foley Square New York, NY 10007 Re: Request to Modify Protective Order (UNDER SEAL)' United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Haddon, Morgan and Foreman, t.c Jeffrey Paglloca 150 East 10th Avenue Denver, Colorado 80203 rti 303.831.7364 FX 303.832.2628 www.hmflaw.com jpaglucaahmflaw.com Dear Jud

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