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order unsealing the deposition material, including Ms. Maxwell's April 2016 deposition transcript. On July 23, over Ms. Maxwell's objection, Judge Preska —who is presiding over the civil case and the litigation about the unsealing of the district court filings —ordered the complete unsealing of Ms. M
CM/ECF, which will send notification of the filing to all counsel of record. I also certify that I mailed a copy of the opening brief to: The Hon. Loretta A. Preska District Judge United States District Court for the Southern District of New York (via United States mail) s/ Nicole Simmons 43 EFTA00075525
a brief stay in order to seek relief in the Second Circuit. There is not a certain mechanism for doing that in an unsealing context but know that the Brown Court at the conclusion of their opinion stated their intent for that panel to maintain jurisdiction over this case for purposes of any appeals taken fro
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
Page: EFTA00018751 →put from the various Does, the lawyers for primarily Sigrid McCawley, a partner at BSF, and counsel for Ms. Maxwell. Judge Preska was obligated by the Brown Court first to identify what was or was not a "judicial document"; second, to determine the presumption of access to the document; and third, to identify
Page: EFTA00018751 →Haddon. Morgan and Foreman. PC Laura A. Menninger www hmacrw tom 2020 Order (Doc. 1096) v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) 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
brief stay in order to seek relief in the Second Circuit. There is not a certain mechanism for doing that in an unsealing context but I know that the Brown Court at the conclusion of their opinior stated their intent for that panel to maintain jurisdiction over this case for purposes of any appeals taken fro
Entities connected to both Loretta A. Preska and the Brown Court

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSON
David Boies
PERSON
Julie K. Brown
PERSONSigrid McCawley
PERSONSecond Circuit
ORGANIZATION
Bradley Edwards
PERSON
Alan Dershowitz
PERSONSweet
PERSON
Stephen Hawking
PERSON
Colorado
LOCATIONJane Doe
PERSONJeffrey Pagliuca
PERSONMartindell
PERSONTy Gee
PERSONSouthern District
LOCATION
Denver
LOCATION
Southern District of New York
ORGANIZATION
Paul Cassell
PERSON
Larry Page
PERSON