Epstein Secrets

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

th a privacy interest in those documents. Numerous civil litigants in the Second Circuit are negotiating protective orders every day in reliance on Martindell and have the right to know that the protective orders may be of little to no utility when their civil opponent seeks to have them used as a tool EF

rom: To: Subject: protective order Date: Tue, 14 Sep 2021 16:20:25 +0000 Attachments: 20cr330 Sealed Opinion Order 6.25.21.pdf Attached is Judge Nathan's opinion on this issue. The relevant cases here are Martindell and Chemical Bank, which are discussed in the opinion. EFTA00013172

16:20:25 +0000 Attachments: 20cr330 Sealed Opinion Order 6.25.21.pdf Attached is Judge Nathan's opinion on this issue. The relevant cases here are Martindell and Chemical Bank, which are discussed in the opinion. EFTA00013172

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

non-parties. Ms. Maxwell assumes that, to this day, Judge Preska has never been told that the government was given all the material as part of the Martindell-avoidance, ex pane processes in front of Judges Sweet, McMahon, and Netbum. The indictment with reference to sealed materials On July 2, 2020, one

be obviated by submission of these materials under seal in the other matters. The reasons this Court should grant the request In contravention of Martindell and its progeny, the government achieved modification of a valid protective order entered in connection with settled civil litigation. Knowing that

GG COHEN & GRESSER LLP Mark S. Cohen Christian R. Evendell March 15, 2021 VIA ECF The Honorable Alison J. Nathan United States District Court uthern District of New York Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: On behalf of

able Alison J. Nathan United States District Court uthern District of New York Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: On behalf of our client, Ghislaine Maxwell, we will be filing the following reply memoranda with accompanying exhibits: I. Reply Memorandum in Su

3 --- PAGE BREAK --- The Honorable Alison J. Nathan March 15, 2021 Page 2 II. Reply Memorandum in Support of Motion Under the Fourth Amendment, Martindell, and the Fifth Amendment to Suppress All Evidence Obtained from the Government's Subpoena to and to Dismiss Counts Five and Six 12. Reply Memoran

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.

v. Ghisiaine Maxwell, 20 Cr. 330 (AJN) Response to Dkt. No. 227, Government's April 21.2021 Letter re Ms. Maxwell's Motions to Suppress Dear Judge Nathan: We write in response to the government's letter about Ms. Maxwell's pending motions to suppress and request for evidentiary hearing (Dkt. No. 227)

's motions to suppress allege violations of the due process clause, the Fourth Amendment, the Fifth Amendment, and the Second Circuit's decision in Martindell v. International Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979). If this Court agrees with Ms. Maxwell's arguments, not only will it suppress all 90

GG COHEN & GRESSER LLP Mark S. Cohen Christian R Fverdell March 15, 2021 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: On behalf

le Alison J. Nathan United States District Court Southern District of New York Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: On behalf of our client, Ghislaine Maxwell, we will be filing the following reply memoranda with accompanying exhibits: I. Reply Memorandum in Su

5 --- PAGE BREAK --- The Honorable Alison J. Nathan March 15, 2021 Page 2 II. Reply Memorandum in Support of Motion Under the Fourth Amendment, Martindell, and the Fifth Amendment to Suppress All Evidence Obtained from the Government's Subpoena to Boies Schiller and to Dismiss Counts Five and Six 12.

r potential witnesses that going forward it will not hesitate to take appropriate action in the face of violations of any relevant rules." Id. judge Nathan said she would ensure "strict compliance" with the rules and "ensure that the Defendant's right to a fair trial will be safeguarded." Id. On July

2016 depositions, both of which were designated "Confidential." Two, the government 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