Epstein Secrets

44, 08/20/2020, 2913556, Pagel of 78 20-2413 United States Court of Appeals for the Second Circuit —against— GHISLAINE MAXWELL, SHARON CHURCHER, JEFFREY EPSTEIN, PlaintiffiAppellee, Defendant-Appellant, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNO

3, Document 44. 08/20/2020, 2913556, Page42 of 78 App.-0816 12 G4LMGIUC 1 four individuals had sexually abused her prior to ever meeting 2 Mr. Epstein. 3 If she has evidence that she already was suffering 4 from depression or some type of mental health disorder before 5 meeting our client, Ms.

t —against— GHISLAINE MAXWELL, SHARON CHURCHER, JEFFREY EPSTEIN, PlaintiffiAppellee, Defendant-Appellan

had sexually abused her prior to ever meeting 2 Mr. Epstein. 3 If she has evidence that she already was suf

ndant's counsel ("Defense Staff"); ii. any expert or potential expert, legal advisor, consultant, or any other individual retained or employed by the Defendant and Defense Counsel for the purpose of assisting in the defense of this case ("Defense Experts/Advisors"); iii. such other persons as hereafter may be authorized by

" individuals, by name, who have "spoken on the public record to the media or in public fora, or in litigation — criminal or otherwise — relating to Jeffrey Epstein or Ghislaine Maxwell."' Specifically, the defendant's proposed protective order differs from the Government's in that it adds a sentence, in its par

defendant's demand that she and her counsel be permitted to name any individuals who have ever publicly identified themselves as a victim of either Epstein or the defendant in any "public fora," and at any time, without limitation, is extraordinarily broad, unnecessary, and inappropriate, and should be

litigation — criminal or otherwise — relating to Jeffrey Epstein or Ghislaine Maxwell."' Specifically, the

dant's counsel ("Defense Staff"); ii. any expert or potential expert, legal advisor, consultant, or any other individual retained or employed by the Defendant and Defense Counsel for the purpose of assisting in the defense of this case ("Defense Experts/Advisors"); iii. such other persons as hereafter may be authorized by

" individuals, by name, who have "spoken on the public record to the media or in public fora, or in litigation — criminal or otherwise — relating to Jeffrey Epstein or Ghislaine Maxwell."' Specifically, the defendant's proposed protective order differs from the Government's in that it adds a sentence, in its par

defendant's demand that she and her counsel be permitted to name any individuals who have ever publicly identified themselves as a victim of either Epstein or the defendant in any "public fora," and at any time, without limitation, is extraordinarily broad, unnecessary, and inappropriate, and should be

litigation — criminal or otherwise — relating to Jeffrey Epstein or Ghislaine Maxwell."' Specifically, the

dant's counsel ("Defense Staff"); ii. any expert or potential expert, legal advisor, consultant, or any other individual retained or employed by the Defendant and Defense Counsel for the purpose of assisting in the defense of this case ("Defense Experts/Advisors"); iii. such other persons as hereafter may be authorized by

" individuals, by name, who have "spoken on the public record to the media or in public fora, or in litigation — criminal or otherwise — relating to Jeffrey Epstein or Ghislaine Maxwell."' Specifically, the defendant's proposed protective order differs from the Government's in that it adds a sentence, in its par

defendant's demand that she and her counsel be permitted to name any individuals who have ever publicly identified themselves as a victim of either Epstein or the defendant in any "public fora," and at any time, without limitation, is extraordinarily broad, unnecessary, and inappropriate, and should be

litigation — criminal or otherwise — relating to Jeffrey Epstein or Ghislaine Maxwell."' Specifically, the

dant's counsel ("Defense Staff"); ii. any expert or potential expert, legal advisor, consultant, or any other individual retained or employed by the Defendant and Defense Counsel for the purpose of assisting in the defense of this case ("Defense Experts/Advisors"); iii. such other persons as hereafter may be authorized by