Epstein Secrets

ion absent "further order of the Court." Protective Order, 20 Cr. 330 (MN) at 1(a), 18 (Exhibit A). As required by that Protective Order and Judge Nathan's Individual Practices in Criminal Cases, counsel initiated a conferral with the U.S. Attorney's Office over the weekend concerning a modification

Case 1:15-cv-07433-LAP Document 1100 Filed 08/10/20 Page 1 of 3 HADDON MORGAN FOREMAN August 10, 2020 Honorable Loretta A. Preska United 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 (

. 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 (Doc. 1069), the Order and Protocol for Unsealing Decided Motions (Doc. 1044) ("Protoco

LBRIEF,_on_behalf of Appellant_Ghislaine_Maxwell,FILED..pdf Inline-Images: image001.jpg FYI. In this brief, Maxwell's attorneys state that if Judge Nathan denies their motion to modify the protective order, they will appeal to the Second Circuit and seek consolidation of that appeal with the appeal fro

their motion to modify the protective order, they will appeal to the Second Circuit and seek consolidation of that appeal with the appeal from Judge Preska's order. From: Sigrid McCawley Sent: Thursday, August 20, 2020 8:27 PM To: `: "; 1S , Subject: FW: New document v. Maxwell (Doc* -, 2d Cir. 20-

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 to the Government's efforts to obtain civ

("the Unsealing Materials") in two, settled, civil matters in which Ms. Maxwell was named a defendant. These materials would be disclosed to Judge Preska and designated as part of the appendix to Ms. Maxwell's appeal in the Second Circuit. We have no objection, at this point, to filing the materials

efense_Motions_FINALJPr oposed_Redactions_Per_Order).pdf Inline-Images: image001.jpg; image002.jpg Thanks for your email. In accordance with Judge Nathan's order, we are writing to confer regarding Exhibit 11 and your cover letter dated March 9, 2021. Attached please find proposed redactions to Exhibi

that you filed under seal (Exhibit H). We understand that the quoted portions of that document are also under seal on the civil docket before Judge Preska. Given those facts, we wanted to double check with you to see whether you in fact want those redactions removed. We will defer to you on whether the

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

their confidential information, and implementing a protocol for maintaining or unsealing the sealed status of thousands of pages of material. Judge Preska sought input from the various Does, the lawyers for primarily Sigrid McCawley, a partner at BSF, and counsel for Ms. Maxwell. Judge Preska was obli

Case 1 15-cv-07433-LAP Document 1078 Filed 07/29/20 Page 1 of 9 HADDON MORGAN FOREMAN 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

www.hmtlaw.com tgeefghmflaw.com Re: Reconsideration of the Court's July 23 Ruling Giuffre v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its Protective Order and punish its violation. Ms. Maxwell's two depositio

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

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

on at Pages 129-134 The government proposes, at pages 129-134, to redact only certain portions of Ms. Maxwell's sealed deposition testimony. Judge Preska has ruled that certain questions and answers are still under seal and subject to the Protective Order in the case. In Ms. Maxwell's Motions, we li

Case 1:20-cr-00330-AJN Document 192 Filed 03/31/21 Page 1 of 3 LAW OFFICES OF BOBBI C. STERNHEIM • Mole • Cell • Fax Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007 Dear Judge Nathan: New York, New York 10011 March 31,

e • Cell • Fax Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007 Dear Judge Nathan: New York, New York 10011 March 31, 2021 United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) This week's filing of the second superseding ind

that right, most especially in light of media coverage and the debacle that occurred during a remote proceeding in a related civil case before Judge Preska. In addition, Ms. Maxwell is requesting a bail hearing at which witnesses will testify regarding the purported strength of the government's case. F

letter to the Court. I'm going to send to the chiefs in 10 minutes so please let me know if you have any edits. Subject: RE: Meet and Confer Judge Nathan agreed with us that sections of the deposition transcripts that appear unredacted in the publicly filed indictment should still be redacted in your

that you filed under seal (Exhibit H). We understand that the quoted portions of that document are also under seal on the civil docket before Judge Preska. Given those facts, we wanted to double check with you to see whether you in fact want those redactions removed. We will defer to you on whether the