Epstein Secrets

ng of Maxwell's Depositions 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 2016 deposition transcript. (See 15 Civ. 7433 (LAP), Dkt.

met that standard." (Id. at 7) (emphasis in original). 8. Unsealing of Maxwell's Depositions 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

130.55 156 Pub. L. No. 101-647 24 Pub. L. No. 103-322 24 Pub. L. No. 108-21 25 Pub. L. No. 109-162 25 Pub. L. No. 109-248 25 Rules Fed. R. App. P. 4(a)(6) 81 Fed. R. Crim. P. 5(f) 188 Fed. R. Crim. P. 6(e) 69 Fed. R. Crim. P. 7(c)(1) 150 Fed. R. Crim. P. 7(d) 159 Fed. R. Crim. P. 1

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

ocument 40, 08/20/2020, 2913550, Page49 of 74 Certificate of Compliance with Rule 32(A) This brief complies with the type-volume limitation of Fed. R. App. P. 32(a)(7)(B). It contains 9,112 words, excluding the parts of the brief exempted by Fed. R. App. P. 32(a)(7)(B)(III). This brief complies with

E MAXWELL, Defendant-Appellant. On Appeal from the U.S. District Court for the Southern District of New York No. 15-CV-7433 (LAP) The Honorable Loretta A. Preska, U.S. District Judge On Appeal from the U.S. District Court for the Southern District of New York No. 20-CR-330 (AJN) The Honorable Alison J. N

(true), that it "has never intervened or appeared in the civil suit" (also true), that it "has had no role in the litigation that resulted in Judge Preska's order" (true again), and that it has no "legal interest in the relief Maxwell seeks in the civil case" (true and extraordinarily revealing). Doc.

9368 Certificate of Compliance with Rule 32(g) Counsel hereby certifies that this response brief complies with the type- volume limitation of Fed. R. App. P. 32(g) and it contains 670 words. s/ Adam Mueller Certificate of Service I certify that on September 23, 2020, I filed Ghislaine Maxwell's Resp

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

oduced to the defense on or about August 12, 2020. As a result, Maxwell could have sought review ofr Nari ll order in the Second Circuit. See Fed. R. App. P. 4(a)(6). Maxwell asks this Court to second-guess a coequal district court's decision to modify a protective order. Putting aside the question of

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 on or about August 12, 2020. As a result, Maxwell could have sought review of Chief Judge McMahon's order in the Second Circuit. See Fed. R. App. P. 4(a)(6). Maxwell asks this Court to second-guess a coequal district court's decision to modify a protective order. Putting aside the question of

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 on or about August 12, 2020. As a result, Maxwell could have sought review of Chief Judge McMahon's order in the Second Circuit. See Fed. R. App. P. 4(a)(6). Maxwell asks this Court to second-guess a coequal district court's decision to modify a protective order. Putting aside the question of

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

e defense on or about August 12, 2020. As a result, Maxwell could have sought review of Chief Judge McMahon's order in the Second Circuit. See Fed. R. App. P. 4(a)(6). Maxwell asks this Court to second-guess a coequal district court's decision to modify a protective order. Putting aside the question of

-mail) Haddon, Morgan and Foreman, P.C. Boies Schiller & Flexner LLP OPPOSING ATTORNEY: Sigrid McCawley Court- Judge/ Agency appealed from: Hon. Loretta A. Preska, District Judge (S.D.N.Y.) Please check appropriate boxes: Has movant notifiedr oposing counsel (required by Local Rule 27.1): lElYes I [No (expla

7) 13 Statutes All Writs Act, 28 U.S.C. § 1651(a) 27 Other Authorities U.S. CONST. amend. V 18, 27 U.S. CONST. amend. VI 18, 27 Rules Fed. R. App. P. 8(a)(2) 13 FED. R. Evm. 401 28 FED. R. EVID. 402 28 FED. R. EVID. 403 28 FED. R. Evm. 404(b) 28 iv EFTA00074908 Case 20-2413, Docume

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

were produced to the defense on or about August 12, 2020. As a result, Maxwell could have sought review of order in the Second Circuit. See Fed. R. App. P. 4(a)(6). Maxwell asks this Court to second-guess a coequal district court's decision to modify a protective order. Putting aside the question of