Epstein Secrets

www.hmllaw.com [email protected] Re: Reconsideration of the Court's July 23 Ruling Giuffie v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its Protective Order and punish its violation. Ms. Maxwell's two depositio

Ces2e.29-12,407413r3cliAlienDtidutinEl t310282 if663615/233/2174ig Plage aoat 9 HADDON MORGAN FOREMAN July 29, 2020 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, P C Ty Gee 150 East

's former counsel, Boies Schiller Fierier, various discovery materials that were subject to the Protective Order. Doc.1071 at 4. The Court rejected Cooper & Kirk's suggestion that it properly was a recipient of the material: [W]hatever Cooper & Kirk's intentions in requesting and obtaining the Maxwell material

Case 1:15-cv-07433-LAP Document 1078 Filed 07/29/20 Page 1 of 9 HADDON MORGAN FOREMAN July 29, 2020 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, r.0 Ty Gee 150 East

www.hmtlaw.com [email protected] Re: Reconsideration of the Court's July 23 Ruling Giuffie v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its Protective Order and punish its violation. Ms. Maxwell's two depositio

's former counsel, Boies Schiller Flexner, various discovery materials that were subject to the Protective Order. Doc.1071 at 4. The Court rejected Cooper & Kirk's suggestion that it properly was a recipient of the material: [W]hatever Cooper & Kirk's intentions in requesting and obtaining the Maxwell material

-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

former counsel, Boies Schiller Flexner, various discovery materials that were subject to the Protective Order. EXHIBYI' 2 at 4. The Court rejected Cooper & Kirk's suggestion that it properly was a recipient of the material: [W]hatever Cooper & Kirk's intentions in requesting and obtaining the Maxwell material