Epstein Secrets

hat the district court (or Ms. Maxwell or Ms. M) unjustifiably delayed public access to the summary judgment papers. This is incorrect. In Lugosch the Second Circuit was understandably impatient with the district court's delay in acting on two newspapers' motion to intervene to unseal the summary judgment filing

Produce Sealed Materials, and to Hold the Orders in Abeyance Pending Disposition of This Motion Appellee Ghislaine Maxwell, through her attorneys Haddon, Morgan and Foreman, P.C., moves the Court (1) to reconsider and vacate its Order to Show Cause and its Order of March 13, 2019, to Produce Sealed

efendant Ghislaine Maxwell OPhintiff DDefendant ['Appellant/Petitioner nAppeUee/Respondent MOVING ATTORNEY: Ty Gee [name of attorney, with fm. Haddon, Morgan and Foreman, P.C. v. Maxwell OPPOSING PARTY: Plaintiff OPPOSING ATTORNEY: Paul Cassell address. phone number and e-mail) S.J. Quinney Co

2021 (Objection to Proposed Redactions of Government's Omnibus Response & Exhibit 5) at 2-3 aemoir detailing her private family matters released by Second Circuit in The Billionaire Playboys Club manuscript). The government also persists in using pseudonyms in this case such as "Minor Victim 2" in place of an

Letter submission Pursuant to this Court's Order of March 29, 2021 (Dkt. No. 189). Regards, Nicole EFTA00103377 www.hmflaw.com Nicole Simmons Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 EFTA00103378

rivacy interests of non- parties ... represents a legitimate basis for sealing judicial documents"). B. Effect of Previous Unsealing of Documents by Second Circuit Plaintiff claims that if a document is already public in another context, then it should be unsealed. She cites no law for this proposition, which

ly 1, 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. 150 East 10th Avenue Denver. CO 80203 Phone: Fax: Attorneys for Ghislaine Maxwell 21 EFTA00074984 Ca a:Mag0743tikI

rm T-I080 (rev.12-13) EFTA00074903 Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page2 of 38 20-2413 United States Court of Appeals for the Second Circuit —against — GHISLAINE MAXWELL, Plaintiff-Appellee, Defendant-Appellant, ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRIC

ttendant EiAppellant/Petkioner DAppellet/Respondent MOVING ATTORNEY: Adam Mueller [name of attorney, with fon, address, phone number and e-mail) Haddon, Morgan and Foreman, P.C. Boies Schiller & Flexner LLP OPPOSING ATTORNEY: Sigrid McCawley Court- Judge/ Agency appealed from: Hon. Loretta A. Pre

have been incorrect remains to be litigated; Ms. Maxwell is not asking this Court to decide that question today. But Ms. Maxwell is seeking in both the Second Circuit and before Judge Preska that the status quo be maintained until the issue can be litigated. If, for example, without the benefit of this informatio

Haddon, Morgan and Foreman. P.c Jeffrey 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. Nath

Haddon, Morgan and Foreman. r.c Jeffrey Paglluca HADDON MORGAN FOREMAN pm August 24, 2020 VIA EMAIL The Honorable Alison J. Nathan United States Di

urt is required to determine whether any countervailing interests outweigh the presumptive right to public access. M. Maxwell, 929 F.3d 41, 49-50 (2d Cir. 2019). Frankly, Ms. Maxwell does not believe that the government has established a countervailing interest compelling enough to justify continued s

N 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. Pagliuca 150 East I Oth Avenue Denver, Colorado 80203 PH 303.831.7364 EX 303.832.2628 wvv.hmftaw.com jpogli

so suppress all evidence derived therefrom. See Wong Sun v. United States, 371 U.S. 471, 488 (1963); United States v. Bailey, 743 F.3d 322, 341-42 (2d Cir. 2014). The government thus cannot avoid inquiry into its conduct simply by pledging not to use the material itself in its case-in-chief. If Ms. Max