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the protective order in that case would prevent the Government from obtaining her testimony and using it in a subsequent criminal case against her. Second Circuit precedent expressly forecloses Maxwell's argument. "A Rule 26(c) protective order, no matter how broad its reach, provides no guarantee that compell
e a sufficient, independent basis to modify a protective order under Martindell notwithstanding the parties' reasonable reliance on that order. See Minpeco S.A. v. Conticommodity Servs., Inc., 832 F.2d 739, 742 (2d Cir. 1987) (citing Martindell, 594 F.2d at 296). Thus, even assuming that the Government shoul
the protective order in that case would prevent the Government from obtaining her testimony and using it in a subsequent criminal case against her. Second Circuit precedent expressly forecloses Maxwell's argument. "A Rule 26(c) protective order, no matter how broad its reach, provides no guarantee that compell
e a sufficient, independent basis to modify a protective order under Martindell notwithstanding the parties' reasonable reliance on that order. See Minpeco S.A. v. Conticommodity Servs., Inc., 832 F.2d 739, 742 (2d Cir. 1987) (citing Martindell, 594 F.2d at 296). Thus, even assuming that the Government shoul
over its records from the civil litigation to the Government. Those documents included transcripts of Maxwell's depositions. The 4 EFTA00066513 Second Circuit later held that the court in the civil case withheld far too many documents from public view and ordered that many of them be made publicly availabl
e a sufficient, independent basis to modify a protective order under Martindell notwithstanding the parties' reasonable reliance on that order. See Minpeco S.A. v. Conticommodity Servs., Inc., 832 F.2d 739, 742 (2d Cir. 1987) (citing Martindell, 594 F.2d at 296). Thus, even assuming that the Government shoul
over its records from the civil litigation to the Government. Those documents included transcripts of Maxwell's depositions. The 4 EFTA00087254 Second Circuit later held that the court in the civil case withheld far too many documents from public view and ordered that many of them be made publicly availabl
e a sufficient, independent basis to modify a protective order under Martindell notwithstanding the parties' reasonable reliance on that order. See Minpeco S.A. v. Conticommodity Servs., Inc., 832 F.2d 739, 742 (2d Cir. 1987) (citing Martindell, 594 F.2d at 296). Thus, even assuming that the Government shoul
over its records from the civil litigation to the Government. Those documents included transcripts of Maxwell's depositions. The 4 EFTA00087233 Second Circuit later held that the court in the civil case withheld far too many documents from public view and ordered that many of them be made publicly availabl
e a sufficient, independent basis to modify a protective order under Martindell notwithstanding the parties' reasonable reliance on that order. See Minpeco S.A. v. Conticommodity Servs., Inc., 832 F.2d 739, 742 (2d Cir. 1987) (citing Martindell, 594 F.2d at 296). Thus, even assuming that the Government shoul
F APPEAL PLEASE TAKE NOTICE that Ghislaine Maxwell, Defendant in the above-captioned case, hereby appeals to the United States Court of Appeals for the Second Circuit from the district court's September 2, 2020, Memorandum Opinion and Order denying her motion to modify the protective order. Pichler v. UNITE, 585
under the collateral order doctrine to review the denial of the motion to modify the Protective Order and the denial of the motion to reconsider."); Minpeco S.A. v. Conticommodity Servs., Inc., 832 F.2d 739, 742 (2d Cir. 1987) (denial of motion to modify protective order is immediately appealable under the c
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
investigation in a criminal action." Botha v. Don King Prods., Inc., No. 97 CIV. 7587 (JGK), 1998 WL 88745, at *3 (S.D.N.Y. Feb. 27, 1998) (citing Minpeco S.A. v. Conticommodity Servs., Inc., 832 F.2d 739, 743 (2d Cir. 1987) and Martindell, 594 F.2d at 297). Judge Sweet, the same judge who approved the civi
Entities connected to both Second Circuit and Minpeco S.A.

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONthe Southern District
LOCATION
Julie K. Brown
PERSON
Supreme Court
ORGANIZATION
David Boies
PERSONJeffrey Pagliuca
PERSON
Lugosch
PERSONMartindell
PERSONOnondaga
LOCATIONColleen McMahon
PERSON
Boies Schiller
ORGANIZATION
ALISON J. NATHAN
ORGANIZATIONthe Second Circuit's
ORGANIZATION
Eric Schmidt
PERSONSalameh
PERSON
Carpenter
PERSON
Robert Gates
PERSONConticommodity Servs
PERSON