Epstein Secrets

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 Southern District of New York 500 Pearl Street New York, NY 10007 Re: 3, 2020 Order (Doc. 1096) v. Ghislaine Maxw

aura A. Menninger 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 EX 303.832.2628 www.hmtlaw.com LMenningergthrntlaw.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

Court going forward, should the unsealing move ahead. Of note, and as Plaintiff will explain to the Court, the parties have agreed to notify all of the Non-Parties at once so that we can understand which Non-Parties object to the unsealing before deciding how to proceed with future redactions. Although this wil

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 Southern District of New York 500 Pearl Street New York, NY 10007 Re: August 3, 2020 Order (Doc. 1096) v. Ghislain

aura A. Menninger 150 East 10th Avenue Denver, Colorado 80203 Pll 303.831.7364 EX 303.832.2628 www.hmtlaw.com LMenninger4hrntlaw.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

Court going forward, should the unsealing move ahead. Of note, and as Plaintiff will explain to the Court, the parties have agreed to notify all of the Non-Parties at once so that we can understand which Non-Parties object to the unsealing before deciding how to proceed with future redactions. Although this wil

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

Court going forward, should the unsealing move ahead. Of note, and as Plaintiff will explain to the Court, the parties have agreed to notify all of the Non-Parties at once so that we can understand which Non-Parties object to the unsealing before deciding how to proceed with future redactions. Although this wil