Epstein Secrets

Menninger ISO East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 EX 303.832.2628 www.hmflaw.com [email protected] Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Objection to Proposed Redactions of Government's Omnibus Response & Exhibit 5 Dear Judge Nathan: On behalf of defendant Ghislain

public access rights under both the common law and First Amendment. Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119 (2d Cir. 2006); Brown v. Maxwell, 929 F.3d 41, 49 (2d Cir. 2019). Ms. Maxwell also specifically asserts her right to an open and public trial pursuant to the Sixth Amendment. Press

.com [email protected] Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Objection to Proposed R

rown v. Maxwell, 929 F.3d 41, 49 (2d Cir. 2019). Ms. Maxwell also specifically asserts her right to an open an

xwell, 929 F.3d 41, 49 (2d Cir. 2019). Ms. Maxwell also specifically asserts her right to an open and public trial pursuant to the Sixth Amendment. Press-Enterprise Co. v. Superior Court (Press-Enterprise II), 478 U.S. 1, 7 (1986). Objections to Redactions Proposed on Pages 1-128 The government's proposed redactio

EFTA00073262 Case 1:15-cv-07433-LAP Document 1111 Filed 09/01/20 Page 4 of 14 • (a) All currently sealed documents filed in support of Defendant Ghislaine Maxwell's motion for summary judgment (ECF No. 540 to 543, inclusive); • (b) All currently sealed documents filed in support of Plaintiff Virginia L. Giuffr

ruary 11, 2020). Access to other judicial documents in this action has already been granted to intervening private parties in interest, see Brown v. Maxwell, 929 F.3d 41 (2d Cir. 2019), and also is the subject of ongoing litigation before this Court. See, e.g., ECF No. 1096-1108. The 1 EFTA00073260 C

F NEW YORK Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-LAP

F.3d 83, 92 (2d Cir. 2004). First, courts must consider "whether the place and process have historically been open to the press and general public. Press-Enterprise Co. v. Superior Court, 478 U.S. 1, 8, 106 S. Ct. 2735 (1986) ("Press-Enterprise If'). Second, courts must consider "whether public access plays a signi

EFTA00077313 Case 1:15-cv-07433-LAP Document 1111 Filed 09/01/20 Page 4 of 14 • (a) All currently sealed documents filed in support of Defendant Ghislaine Maxwell's motion for summary judgment (ECF No. 540 to 543, inclusive); • (b) All currently sealed documents filed in support of Plaintiff opposition to Def

ruary 11, 2020). Access to other judicial documents in this action has already been granted to intervening private parties in interest, see Brown v. Maxwell, 929 F.3d 41 (2d Cir. 2019), and also is the subject of ongoing litigation before this Court. See, e.g., ECF No. 1096-1108. The EFTA00077311 Case

T SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-LAP

F.3d 83, 92 (2d Cir. 2004). First, courts must consider "whether the place and process have historically been open to the press and general public. Press-Enterprise Co. v. Superior Court, 478 U.S. 1, 8, 106 S. Ct. 2735 (1986) ("Press-Enterprise If'). Second, courts must consider "whether public access plays a signi

v. Maxwell, — F.Supp.3d — (2018) 2018 WL 4062649 Only the Westlaw citation is currently available. United States District Court, S.D. New York. Plaintiff,

F.Supp.3d — (2018) 2018 WL 4062649 Only the Westlaw citation is currently available. United States District Court, S.D. New York. Plaintiff, v. Ghislaine MAXWELL, Defendant. 15 Civ. 7433 i Signed 08/27/2018 Synopsis Background: Following settlement of plaintiff's action for defamation, news media and inv

s District Court, S.D. New York. Plaintiff, v. Ghislaine MAXWELL, Defendant. 15 Civ. 7433 i Signed 08/2

her claim of defamation by Maxwell arising out of the Maxwell January 3 Statement. alleged she was the "victim

ppression `is essential to preserve higher values and is narrowly tailored to serve that interest.' " Hartford Courant Co., 380 F.3d at 96 (quoting Press-Enterprise Co. v. Superior Court of Cal., Riverside Cnty., 464 U.S. 501, 510, 104 S.Ct. 819, 78 L.Ed.2d 629 (1984) ) (internal citation omitted). What must be dete

erg’s former investors rekindled the lawsuit against Epstein, but the case was dropped in October. Epstein and his associate, British-born socialite Ghislaine Maxwell, were also accused in a 2015 federal civil suit of organizing underage sex parties on his private plane, nicknamed “The Lolita Express,” and at Epste

in a 2015 federal civil suit of organizing underage sex parties on his private plane, nicknamed “The Lolita Express,” and at Epstein’s various homes. Maxwell, who has never been charged with wrongdoing, has denied allegations made in the lawsuit that she was Epstein’s “madam.” The suit, filed by victim Vir

Epstein and his associate, British-born socialite Ghislaine Maxwell, were also accused in a 2015 federal civi

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