Epstein Secrets

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 of the Protective Order to share the information with this Court and the Second Circuit. Barring agreeme

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

purported strength of the government's case. Further, we request that these proceedings be scheduled to coincide with an evidence review session at the U.S. Attorney's Office to be attended by Ms. Maxwell with counsel. Your consideration is greatly appreciated. Very truly yours, gag C. 544,14.:..n. BOBBI C. STERNHEIM

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

District of New York. Contrary to the government's portrayal of events, what happened here is that a prosecutor from the public corruption unit of the United States Attorney's Office, in an a parte proceeding, affirmatively misled Chief Judge McMahon to circumvent a Protective Order entered by one of her colleagues. The prosecut

dmits the following facts are true: • On February 29, 2016, AUSA M, the Human Trafficking Coordinator and Project Safe Childhood Coordinator for the U.S. Attorney's Office for the Southern District of New York, Ex. J, p 1, met with Peter Skinner of Boies Schiller, Stan Pottinger, and Brad Edwards, who represented M,

— 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

District of New York. Contrary to the government's portrayal of events, what happened here is that a prosecutor from the public corruption unit of the United States Attorney's Office, in an a parte proceeding, affirmatively misled Chief Judge McMahon to circumvent a Protective Order entered by one of her colleagues. The prosecut

] or anyone else." Id. 7 Two other aspects to the privilege log are notable: (a) In the litigation, Boies Schiller did not produce its emails with the U.S. Attorney's Office to Maxwell, despite the fact that they were directly responsive to a Request for Production of Documents Maxwell served just a couple of weeks afte

d— because of a strong expectation of continued confidentiality. 929 F.3d 4, 48, 122 (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

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

mendment to Suppress All Evidence Obtained from the government's Subpoena to Boies Schiller and to Dismiss Counts Five and Six upon the following: U.S. Attorney's Office, SDNY One Saint Andrew's Plaza New York, NY 10007 s/ Christian R. Everdell 15 EFTA00019016