Epstein Secrets

Produce Sealed Materials, and to Hold the Orders in Abeyance Pending Disposition of This Motion Appellee Ghislaine Maxwell, through her attorneys Haddon, Morgan and Foreman, P.C., moves the Court (1) to reconsider and vacate its Order to Show Cause and its Order of March 13, 2019, to Produce Sealed

efendant Ghislaine Maxwell OPhintiff DDefendant ['Appellant/Petitioner nAppeUee/Respondent MOVING ATTORNEY: Ty Gee [name of attorney, with fm. Haddon, Morgan and Foreman, P.C. v. Maxwell OPPOSING PARTY: Plaintiff OPPOSING ATTORNEY: Paul Cassell address. phone number and e-mail) S.J. Quinney Co

Street, Salt Lake City, UT 84112-0730 303.831.7364; [email protected] 801.585.5202; [email protected] Court- Judge/ Agency appealed from: Hon. Robert W. Sweet, District Judge (S.D.N.Y.) Please check appropriate boxes: Has movant notified posing counsel (required by Local Rule 27.1): {} Yes No (explain)

Haddon. Morgan and Foreman, e c Laura A. Menninger II A I> DO N MORGAN FOREMAN April 6. 2016 Via Email ISO East 10th Avenue Denver. Colorado 80203

n action brought by Plaintiff :aka Jane Doe #3). During the course of discovery disputes Ms. Sigrid McCawley, counsel for represented to the Hon. Robert W. Sweet that my client is "under investigation" by an unidentified law enforcement agency. She argues, therefore, that she can withhold documents based ini

rvenors-Appellants No. 18-2868 Appellee Maxwell's Response to Order to Show Cause EFTA00794214 Appellee Ghislaine Maxwell, through her attorneys Haddon, Morgan and Foreman, P.C., submits this Response to the Court's Order to Show Cause ("OTSC"). I. Objections to the Order to Show Cause. For the r

fy that on March 19, 2019, I served via CM/ECF a copy of this Appellee Maxwell's Response to Order to Show Cause on the following persons: The Hon. Robert W. Sweet District Judge United States District Court for the Southern District of New York (via United States mail) Christine N. Walz (christine.walz@hk

Y, on the brief), Holland & Knight LLP, Miami, FL, for Intervenors-Appellants Julie Brown and Miami Herald. TY GEE (Adam Mueller, on the brief), Haddon, Morgan and Foreman, P.C., Denver, CO, for Defendant-Appellee Ghislaine Maxwell. 3 EFTA00092310 PAUL G. CASSELL (Sigrid S. McCawley, Boies Sch

mi Herald Company (with reporter Julie Brown) appeal from certain orders of the United States District Court for the Southern District of New York (Robert W. Sweet, Judge) denying their respective motions to unseal filings in a defamation suit. We conclude that the ' The Clerk of Court is directed to amend the