Epstein Secrets

ow precise. complete statement of relief sought: Order to Show Cause and March 13 Order should be reconsidered and vacated MOVING PARTY: Defendant Ghislaine Maxwell OPhintiff DDefendant ['Appellant/Petitioner nAppeUee/Respondent MOVING ATTORNEY: Ty Gee [name of attorney, with fm. Haddon, Morgan and Foreman

Case 18-2868, Document 141, 03/15/2019, 2519388, Page2 of 27 IN THE UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT Plaintiff-Appellee, v. GHISLAINE MAXWELL, Defendant, v. SHARON CHURCHER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, Intervenors-Appellants No. 18-

ment 141, 03/15/2019, 2519388, Page4 of 27 has the ability to balance the public's interest in access to the discovery in court filings against Ms. Maxwell's and the non-parties' compelling interests. This is an extraordinary case. Ms. for more than a decade has actively pursued publicity and money fo

access to the discovery in court filings against Ms. Maxwell's and the non-parties' compelling interests. Thi

Gambale v. 22 EFTA00791891 Case 18-2868, Document 141, 03/15/2019, 2519388, Page24 of 27 Deutsche Bank AG, 377 F.3d 133, 142 n.7 (2d Cir. 2004). Reliance may be unreasonable if the protective order is temporary or limited, see id., or if it may be modified by anyone, see Lugosch, 435 F.3d at 126.51n

i just asked who is good at cross. ? ar= you? On Sun, Feb 19, =017 at 2:48 PM, wrote: I see now the media is using this acosta nomination and the Maxwell cas= in NY to once again get your name in the mix. I sure hope the lawye=(s) in this Maxwell case is someone who cross-examines for a living if thi

now the media is using this acosta nomination and the Maxwell cas= in NY to once again get your name in the mi

sume you had a lawyer representing you when you brought=the underlying case at issue. I assume you have, among other things,=a defense based on your Reliance in the advice of counsel concerning the v=ability/legitimacy of the lawsuit that was brought. Good luck. Hope this puts all if this litigation behi

The lethargic state of global credit markets (in particular, in Europe), ma' make it difficult for financial sponsors to obtain favorable PR305378-MAXWELL_ Blackstone Real Estate Partners Europe V 73 CONFIDENTIAL UBSTERRAMAR00001920 EFTA00237551 Risk Factors and Potential Conflicts of Interest f

urrent Income from an Investment to its ER305378-MAXWELL Blackstone Real Estate Partners Europe V 27 CO

ration of any notices, filings, periodic reports and/or other materials as may be required in relation to any European Economic Area member states. Reliance on Portfolio Company Management. In many instances, the day-to-day operations of each Investment will be the responsibility of the Investment's mana

e costly and occupy significant staff time and resources. Any such inquiry, investigation or enforcement proceeding could include civil or criminal SAXWELL II-35 CONFIDENTIAL UBSTERRAMAR00001398 EFTA00237044 proceedings resulting in a censure, fine, penalty and/or other sanction, including asset f

th following the date on which notice of the Trigger Event is given (the "Transition Period"), and thereafter until the Special Withdrawal Date (as MAXWELL I-30 CONFIDENTIAL UBSTERRAMAR00001307 EFTA00236953 defined below), withdrawals may not be made, and (subject to the next sentence) withdrawal

s from the other Feeder Funds' investors, which could adversely affect the value of an investor's interests. Business Dependent on Key Individuals; Reliance on Portfolio Managers The success of the Fund is significantly dependent upon the expertise of a number of individuals, including, Israel A. Englan

OVIDED TO PROSPECTIVE INVESTORS IN SUCH ER305378-MAXWELL Blackstone Real Estate Partners Europe V 127 CO

nd) as permitted by the Underlying Fund, in the Member Designee's sole discretion and without prior notice to, or consent from, the Members. 2.2. Reliance by Third Parties. In dealing with the Member Designee, the Administrator and their duly appointed agents, no Person shall be required to inquire as

r until the Special Withdrawal Date (as ML281817-MAXWELL I-30 CONFIDENTIAL UBSTERRAMAR00002360 EFTA002

s from the other Feeder Funds' investors, which could adversely affect the value of an investor's interests. Business Dependent on Key Individuals; Reliance on Portfolio Managers The success of the Fund is significantly dependent upon the expertise of a number of individuals, including, Israel A. Englan