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e defense attorneys' alleged efforts to "pique" the Government's interest "in a second meeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020,
irc ompe "unalMer eluded e Govan nut that ed to hasis in 8. Unsealing of Maxwell's Depositions v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judgg Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April
ing, and related to, Maxwell's April 74 EFTA00100041 2016 deposition transcript. (See 15 Civ. 7433 (LAP), Dkt. No. 1077). Maxwell appealed Judge Preska's order, arguing that the court abused its discretion in ordering the unsealing of the deposition materials and that Maxwell's interests outweighed
e defense attorneys' alleged efforts to "pique" the Government's interest "in a second meeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020,
8. Unsealing of Maxwell's Depositions Three months after Chief Judge McMahon issued her Order, Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April
ge McMahon issued her Order, Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April 74 EFTA00077706 2016 deposition transcript. (See 15 Civ
e defense attorneys' alleged efforts to "pique" the Government's interest "in a second meeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020,
8. Unsealing of Maxwell's Depositions Three months after Chief Judge McMahon issued her Order, Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April
ge McMahon issued her Order, Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April 74 EFTA00039521 2016 deposition transcript. (See 15 Civ
e defense attorneys' alleged efforts to "pique" the Government's interest "in a second meeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020,
inal). 8. Unsealing of Maxwell's Depositions Three months after Chief Judge McMahon issued her Order, v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April
ief Judge McMahon issued her Order, v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April 74 EFTA00103099 2016 deposition transcript. (See 15 Civ
nk Nat. Ass 'n v. PHL Variable Ins. Co., No. 12 CIV. 6811 CM JCF, 2012 WL 5395249 (S.D.N.Y. Nov. 5, 2012) 2 iii EFTA00100289 Other Authorities Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 11 Rules
ability analysis in this case," however, "is predicated on an assessment of the actions that might have been taken by third parties," such as Judge Preska and the Miami Herald, who are "not acting at the behest of the police." Id. "Such an analysis is inherently speculative." Id. In fact, unlike every
dt, 105 F.3d 82 (2d Cir. 1997) 23 Wang v. Reno, 81 F.3d 808 (9th Cir. 1996) 2 Young v. United States, 481 U.S. 787 (1987) 24 Other Authorities Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 11 U.S.
— because of a strong expectation of continued confidentiality. 929 F.3d 4, 48, n.22 (2d Cir. 2019) (citing Fed. R. Civ. P. 5.2). So, too, has Judge Preska redacted substantial material from the documents she has released on remand from the Second Circuit, again reflecting that Maxwell reasonably relied
nk Nat. Ass 'n v. PHL Variable Ins. Co., No. 12 CIV. 6811 CM JCF, 2012 WL 5395249 (S.D.N.Y. Nov. 5, 2012) 2 iii EFTA00097333 Other Authorities Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 11 Rules
ability analysis in this case," however, "is predicated on an assessment of the actions that might have been taken by third parties," such as Judge Preska and the Miami Herald, who are "not acting at the behest of the police." Id. "Such an analysis is inherently speculative." Id. In fact, unlike every
nk Nat. Ass 'n v. PHL Variable Ins. Co., No. 12 CIV. 6811 CM JCF, 2012 WL 5395249 (S.D.N.Y. Nov. 5, 2012) 2 iii EFTA00097651 Other Authorities Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 11 Rules
ability analysis in this case," however, "is predicated on an assessment of the actions that might have been taken by third parties," such as Judge Preska and the Miami Herald, who are "not acting at the behest of the police." Id. "Such an analysis is inherently speculative." Id. In fact, unlike every
urces, "a second meeting occurred." However, the Article cites another anonymous source as "insist[ing] [a second meeting] never happened." 36 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020,
materials. Giuf•e v. Maxwell, No. 20-2413 (2d Cir.) (Dkt. No. 140-1 at 2). On October 19, 2020, the Second Circuit found that Judge Preska "correctly held that the deposition materials are judicial documents to which the presumption of public access attaches, and did not abuse its discr
L Variable Ins. Co., No. 12 CIV. 6811 CM JCF, 2012 WL 5395249 (S.D.N.Y. Nov. 5, 2012) 2 iii EFTA00018999 --- PAGE BREAK --- Other Authorities Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 11 Rules
Page: EFTA00019000 →ability analysis in this case," however, "is predicated on an assessment of the actions that might have been taken by third parties," such as Judge Preska and the Miami Herald, who are "not acting at the behest of the police." Id. "Such an analysis is inherently speculative." Id. In fact, unlike every
Page: EFTA00019007 →Entities connected to both Stephen Rex Brown and Loretta A. Preska

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSON
Julie K. Brown
PERSON
Stephen Hawking
PERSON
David Boies
PERSON
Prince Andrew
PERSONthe Southern District
LOCATIONSecond Circuit
ORGANIZATION
Bradley Edwards
PERSON
Virginia Giuffre
PERSONJeffrey Pagliuca
PERSONSigrid McCawley
PERSONColleen McMahon
PERSON
Schiller
PERSON
George W. Bush
PERSON
Michael Cohen
PERSONSweet
PERSONJane Doe
PERSON
Southern District of New York
ORGANIZATIONMartindell
PERSON