Epstein Secrets

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

Maxwell and other third parties. The ten discrete items to be filed ("the Material") are not confidential and disclosure confined to the Honorable Loretta Preska and the Second Circuit Court of Appeals, under seal, ' Ms. Maxwell seeks leave to file this Letter Motion under seal because it relates and refers t

s ex-girlfriend, Ghislaine Maxwell, refused Thursday to ban prosecutors or lawyers for alleged victims from commenting publicly." US District Judge Alison J. Nathan "said in a written order that she expects anyone involved in the case to exercise `great care' to comply with rules designed to ensure a fair trial,

terials related to her, while another judge refused to block prosecutors and lawyers from publicly discussing her criminal case." US District Judge Loretta Preska in Manhattan "directed the release of large portions of more than 80 documents from a 2015 civil lawsuit against Maxwell, the British socialite now

's ex-girlfriend, Ghislaine Maxwell, refused Thursday to ban prosecutors or lawyers for alleged victims from commenting publicly." US District Judge Alison J. Nathan "said in a written order that she expects anyone involved in the case to exercise 'great care' to comply with rules designed to ensure a fair trial

terials related to her, while another judge refused to block prosecutors and lawyers from publicly discussing her criminal case." US District Judge Loretta Preska in Manhattan "directed the release of large portions of more than 80 documents from a 2015 civil lawsuit against Maxwell, the British socialite now

Strictly Private and Confidential Hon. Alison J. Nathan Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007 By Email ONLY Dear Judge Nathan, Date 21.t April 2021 Our Ref

nd online. Having then become aware of the right to seek redaction she instructed this firm to represent her and we made such application to Judge Loretta Preska which was granted. We signed a Non-Party Notice and Order and were able to obtain the relevant documents to have our client's name redacted. use t

MANLEYS SOLICITORS Strictly Private and Confidential Hon. Alison J. Nathan Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007 By Email ONLY Date 21.t April 2021 Our Ref MJM/TAYO/1 Your Re

nd online. Having then become aware of the right to seek redaction she instructed this firm to represent her and we made such application to Judge Loretta Preska which was granted. We signed a Non-Party Notice and Order and were able to obtain the relevant documents to have our client's name redacted. Manla

's ex-girlfriend, Ghislaine Maxwell, refused Thursday to ban prosecutors or lawyers for alleged victims from commenting publicly." US District Judge Alison J. Nathan "said in a written order that she expects anyone involved in the case to exercise 'great care' to comply with rules designed to ensure a fair trial

terials related to her, while another judge refused to block prosecutors and lawyers from publicly discussing her criminal case." US District Judge Loretta Preska in Manhattan "directed the release of large portions of more than 80 documents from a 2015 civil lawsuit against Maxwell, the British socialite now