Epstein Secrets

natively, that a district court has discretion to award costs to the defendant.”); see also Carter v. Inc. Vill. of Ocean Beach, 759 F.3d 159, 165 (2d Cir. 2014) (disclaiming prior Second Circuit dicta which stated that “generally the defendant is not considered the prevailing party when, as here, there

has discretion to award costs to the defendant.”); see also Carter v. Inc. Vill. of Ocean Beach, 759 F.3d 159, 165 (2d Cir. 2014) (disclaiming prior Second Circuit dicta which stated that “generally the defendant is not considered the prevailing party when, as here, there is a voluntary dismissal of the action

icago, IL 60606 [email protected] s/ Nicole Simmons Respectfully submitted, s/ Laura A. Menninger Laura A. Menninger (LM-1374) HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 [email protected] Attorneys for Ghislaine Maxwell Case

in the Criminal Action from Judge Nathan forthwith to permit sharing the information with this Court, ex parte and in camera if necessary, and with the Second Circuit (likewise under seal if necessary). EFTA00018580 --- PAGE BREAK --- Case 1:15-cv-07433-LAP Document 1100 Filed 08/10/20 Page 2 of 3 Honorable L

ed States District Court outhern District of New York ew or 0007 Re: Au 3, 2020 Order (Doc. 1096) v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Haddon, Morgan and Foreman, P C Laura A. Menninger Denver, Colorado 80203 wvow.hmilaw.com Dear Judge Preska: I write in response to the Court's Order of August 3, 2020 (Do

sclosure of confidential material in ME v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) and a related appeal in the United States Court of Appeals for the Second Circuit, 20-2413. We intend to ask Judge Nathan for permission to refer to and attach, as exhibits, the above referenced discovery materials which relate t

H A D D O N MORGAN FOREMAN Haddon, Morgan and Foreman, P c Jeffrey S. Paglluca P11 IIIIIIIMPPOIMIIIMPIIIMPIO www.hmflaw.com August 9, 2020 VIA EMAIL Assistant United States Attorney New York, New

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

r seal, as exhibits 1-10. Although marked by the government as "Confidential," the Materials are not "Confidential" as that term has been defined by the Second Circuit. They consist of ex pane pleadings filed by the government, ex pane transcripts, and ex pane rulings. Boies, Schiller & Flexner ("BSF') lawyers, coo

iami Herald appealed on September 28, 2018. On July 3, 2019 the Second Circuit reversed Judge Sweet's ruling. Brown v. Maxwell, 929 F.3d 41, 44-45 (2d Cir. 2019). Upon the issuance of the mandate, on August 9, 2019, it largely unsealed the summary judgment materials to the public and the press and reman

REMAN July 29, 2020 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, P.0 Ty Gee 150 East 10th Avenue Denver, Colorado 80203 ni 303.831.7364 rx 303.832.2628 www.hmtlaw.com tgeefghmflaw.com Re: Reconsideration of

other than plaintiff] who was 17 at this point." Id. 121. None of these questions and answers was used in the summary judgment papers or released by the Second Circuit. The transcript containing this testimony is sealed. 2. The Court should commence proceedings to vindicate the government and plaintiff's violation

nment had no ability legally to obtain the deposition transcripts. In Martindell v. International Telephone and Telegraph Corp., 594 F.2d 291, 293 (2d Cir. 1979), cited with approval in In re Teligent, Inc., 640 F.3d 53, 58 (2d Cir. 2011), the government moved in a civil action to which it was not a par