Epstein Secrets

That is the definition. 24 However, I'm also going to ask the parties to agree 25 upon an order that would expand the confidentiality agreement SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00076418 Case 20-2413, Document 44. 08/20/2020, 2913556, Page37 of 78 App.-0811 7 G4LMGIUC 1 to this exte

cole Simmons 2 EFTA00076390 Case Gaga4.407741333-IDARn-Offiuhiefle3MOQIXD, Filki5B33fface9:4191;91 of 4 App.-0783 United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. NON-REDACTED DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF

ion as an officer of this Court. At this time, counsel is not at liberty to disclose the information because it is subject to a protective order in the Criminal Action, which forbids its use "for any civil proceeding or any purpose other than the defense" of the criminal action absent "further order of the Court."

Case 1:20-cr-00330-AJN Document 41 Filed 08/13/20 Page 1 of 5 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mob Building One Saint Andrew's Plaza New York. New York 10007 August 13, 2020 VIA ECF The Honorable Alison J. Nathan

urportedly had received "critical new information" from the criminal case that it could not disclose "because it is subject to a protective order in the Criminal Action," and further noting publicly a desire to seek modification of the protective order in thi use such materials in the civil case, which the protect

33-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 Maxwell, No. 15 Civ. 7433 (LAP) Haddon, Morgan and f

ion as an officer of this Court. At this time, counsel is not at liberty to disclose the information because it is subject to a protective order in the Criminal Action, which forbids its use "for any civil proceeding or any purpose other than the defense" of the criminal action absent "further order of the Court."

U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Motto Building One Saint Andrew's Plaza New York. New York 10007 August 13, 2020 VIA ECF The Honorable Alison J. Nath

urportedly had received "critical new information" from the criminal case that it could not disclose "because it is subject to a protective order in the Criminal Action," and further noting publicly a desire to seek modification of the protective order in this case to use such materials in the civil case, which the

33-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. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Haddon, Morgan

ion as an officer of this Court. At this time, counsel is not at liberty to disclose the information because it is subject to a protective order in the Criminal Action, which forbids its use "for any civil proceeding or any purpose other than the defense" of the criminal action absent "further order of the Court."

Case 1:20-cr-00330-AJN Document 41 Filed 08/13/20 Page 1 of 5 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mob Building One Saint Andrew's Plaza New York. New York 10007 August 13, 2020 VIA ECF The Honorable Alison J. Nathan

urportedly had received "critical new information" from the criminal case that it could not disclose "because it is subject to a protective order in the Criminal Action," and further noting publicly a desire to seek modification of the protective order in this') use such materials in the civil case, which the prot