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e.24h24/43134.01FrietibtOrtlefifitin0a0le28013,8111$2eafiabef146f 22 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Reply In Support Of Iler Objections to tnsealinu Sealed Materials Laura A. Menninger Jeffre
iabef146f 22 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Reply In Support Of Iler Objections to tnsealinu Sealed Materials Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C
ine Maxwell says she was Epstein's employee not his madam," MIAMI HERALD (Mar. 18, 2020) (quoting Sigrid McCawley, "It is absolutely appalling that Ghislaine Maxwell, who committed crimes with Epstein against these victims, is seeking to drain funds from the very estate that should be paying the Epstein victims'
ISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Reply In Support Of Iler Objections to tnsealin
een admitted in a court of law; opening them up to the press presents an opportunity for abuse and misuse of the court's files. See United States v. Gatto, 17-CR-686 (LAK), 2019 WL 4194569, at *4 (S.D.N.Y. Sept. 3, 2019) ("documents merely shown to witnesses or otherwise discussed in Court but not off
son J. Nathan United States District Court Southern District of New York United States Courthouse New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully requests that Your Honor allow us to arrange for the provision of secure high-spe
BY ORDERED THAT Courtroom Connect, a Southern District of New York contracted vendor, may provide the Government in the United States v. Glzislaine Maxwell, S2 20 Cr. 330 (AJN), with an Internet connectivity feed for the duration of the trial proceedings, set to begin on Monday, November 29, 2021. Court
New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: Th
working personnel. Many trials in federal courts have utilized a high-speed connection to the Internet in the courtroom, including United States v. Gatto, 17 Cr. 686 (LAK). If Your Honor is agreeable to these arrangements, the Government respectfully requests that you sign the enclosed order permitti
White Plains Division" and a "Manhattan Division." (See, e.g., Def. Mot. 9 at 2 ("On June 29, 2020, the government filed a sealed indictment of Ms. Maxwell in the Manhattan Division of this Court. The government has conceded that Ms. Maxwell's indictment was obtained using a grand jury seated in White
020, the government filed a sealed indictment of Ms. Maxwell in the Manhattan Division of this Court. The gov
her recent trials in this District, and in those cases witnesses have typically been disclosed approximately three to four weeks before trial. E.g., Gatto, 17 Cr. 686 (LAK); Blaszczak, 17 Cr. 357 (LAK); Skelos, 15 Cr. 317 (KMW); Levin, 15 Cr. 101 (KBF); Silver, 15 Cr. 93 (VEC); Ulbricht, 14 Cr. 68 (KB
he requisite elements is largely a question for a jury. See Patrick John McGinley, 21 Fla. Prac., Elements of an Action § 50:1 (2013-2014 ed.)(citing Gatto v. Publix Supermarket, Inc., 387 So. 2d 377 (Fla. 3d DCA 1980)). The usual case of abuse of process involves some form of extortion. Scozari v. Baro
Page: HOUSE_OVERSIGHT_013313 →f Podhurst Orseck. See Complaint, Jane Doe 102 v. Epstein (Exhibit “B”). As recounted in detail in this Complaint, Jane Doe 102 was 15 years old when Ghislaine Maxwell discovered her and lured her to Epstein’s house. Maxwell and Epstein forced her to have sex with both of them and within weeks Maxwell and Epstein we
Page: HOUSE_OVERSIGHT_013338 →“B”). As recounted in detail in this Complaint, Jane Doe 102 was 15 years old when Ghislaine Maxwell discovered her and lured her to Epstein’s house. Maxwell and Epstein forced her to have sex with both of them and within weeks Maxwell and Epstein were flying her all over the world. According to the Compla
Page: HOUSE_OVERSIGHT_013338 →s personal pilot), Larry Harrison (Epstein’s personal pilot), Louella Rabuyo (Epstein’s housekeeper), Nadia Marcinkova (Epstein’s live-in sex slave), Ghislaine Maxwell (manager of Epstein’s affairs and businesses), Mark Epstein (Epstein’s brother), and Fane Banasiak (Epstein’s house manager) It was nearly im
Page: HOUSE_OVERSIGHT_013345 →Entities connected to both Ghislaine Maxwell and Gatto

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
United States
LOCATION
George W. Bush
PERSON
Alan Dershowitz
PERSON
Department of Justice
ORGANIZATIONLeon Black
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Julie K. Brown
PERSON
Virginia Giuffre
PERSONMaria Farmer
PERSONFBI
ORGANIZATIONJane Doe
PERSON
Sarah Kellen
PERSON
Palm Beach
LOCATION
Kenneth Marra
PERSON
Paul Cassell
PERSON
Scarlett Johansson
PERSON
Wilbur Ross
PERSON