Epstein Secrets

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s impacting the privacy and due process rights of Ms. Maxwell and other third parties. The ten discrete items

ges with documents in their possession related to the Maxwell civil matters but presumes they are the same. Pa

ct Court Southern District of New York 40 Foley Square New York, NY 10007 Re: Request to Modify Protective Order (UNDER SEAL)' United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Haddon, Morgan and Foreman, t.c Jeffrey Paglloca 150 East 10th Avenue Denver, Colorado 80203 rti 303.831.7364 FX 303.832.2628

18 of this Court's Protective Order (Doc. # 36), requests that the Court enter an Order allowing her to refer to and file under seal in Giuffre v. Maxwell, 15-cv-5433 (LAP), and a related Second Circuit appeal, Giuffre v. Maxwell, No. 20- 2413 (the "Other Matters"), certain discovery materials produced

Protective Order (UNDER SEAL)' United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Haddon, Morgan and Fore

ed in state court litigation); Rosales-Martinez v. Palmer, 753 F.3d 890, 894 (9th Cir. 2014) (can take judicial notice of proceedings on any court); Fletcher v. Menard Correctional Center, 623 F.3d 1171, 1173 (7th Cir. 2010) (court can take judicial notice of other proceedings in a case involving the sam

e the charges against him were pending. OA (citing United States v. Epstein 19 Cr. 490 (RMB), Nolle Prosequi (Dkt. No. 52))) B. The Prosecution of Ghislaine Maxwell On June 29, 2020, Ghislaine Maxwell was indicted by a grand jury in this District on "one count of conspiracy to entice minors to travel to engage

Prosequi (Dkt. No. 52))) B. The Prosecution of Ghislaine Maxwell On June 29, 2020, Ghislaine Maxwell was

ntent to engage in criminal sexual activity"; "and two counts of perjury." (Third Comey Decl. (Dkt. No. 59) 1 6) On December 29, 2021, a jury found Maxwell guilty of enticing a minor to travel to engage in illegal sex acts, transporting minors with the intent to engage in criminal sexual activity, and

ine issue of material fact where none would otherwise exist.'" Hicks v. Baines, 593 F.3d 159, 166 (2d Cir. 2010) (alterations in original) (quoting Fletcher v. Atex, Inc., 68 F.3d 1451, 1456 (2d Cir. 1995)). 6 EFTA00038657 --- PAGE BREAK --- Case 1:17-cv-03956-PGG Document 64 Filed 06/25/24 Page 7 of