Epstein Secrets

RNOVICH, DBA CERNOVICH MEDIA Intervenors. ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, 15-CV-7433 (LAP) Ghislaine Maxwell's Opening Brief Ty Gee Adam Mueller HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Den r 2 Tel. Attorneys for Defendant-Appellant Ghisla

motion to unseal and the first appeal 6 The remand, the arrest, and the indictment. 7 The order unsealing the deposition material, including Ms. Maxwell's April 2016 deposition transcript 11 Events after the filing of the notice of appeal and the critical new information 13 Summary of the Argument

C. 150 East 10th Avenue Denver, CO 80203 Tel 303.831.7364 Fax 303.832.2628 [email protected] [email protected] Counsel for Defendant-Appellant Ghislaine Maxwell 42 EFTA00075524 Case 20-2413, Document 40, 08/20/2020, 2913550, Page49 of 74 Certificate of Compliance with Rule 32(A) This brief comp

rder unsealing the deposition material, including Ms. Maxwell's April 2016 deposition transcript 11 Events a

: [T]here is no question that the plain terms of the Maxwell Protective Order would justify such an expectati

2 (2d Cir. 1994) Press-Enter. Co. a Superior Ct., 464 U.S. 501 (1984) S.E.C. v. TheStreet.Com, 273 F.3d 222 (2d Cir. 2001) passim 34 37 passim Seattle Times Co. v. Rhinehart, 467 U.S. 20 (1984) 24 State a Cady, 414 P.3d 974 (Utah Ct. App. 2018) 19 United States v. Amodeo, 44 F.3d 141 (2d Cir. 1995) ("Amod

bpoena. The application is granted. I. Background A. The Protective Order In September 2015, Virginia L. Giuffre commenced a civil suit against Ghislaine Maxwell, alleging that Maxwell had defamed Giuffre by stating that Giuffre was not the victim of sex crimes perpetrated by, among others, Maxwell a

e application is granted. I. Background A. The Protective Order In September 2015, Virginia L. Giuffre commenced a civil suit against Ghislaine Maxwell, alleging that Maxwell had defamed Giuffre by stating that Giuffre was not the victim of sex crimes perpetrated by, among others, Maxwell and Jeffre

scovery, and (3) does not restrict the dissemination of the information if gained from other sources," it is not improvidently granted. Id (quoting Seattle Times Co. v. Rhinehart, 467 U.S. 20, 37 (1984)); see also FragranceNetcom, Inc. v. Fragrancel.com, Inc., No. 06-cv-2225, 2010 WL 11606632, at •4 14 SDNY_GM_

has filed an application for modification of a March 18, 2016 pretrial protective order, entered by the late Hon. in a civil defamation action, v. Maxwell, No. 15-cv-7433 (S.D.N.Y.) ("the Action"), in order to permit the law firm of Boles Schiller Flexner LLP ("Boies Schiller") to comply with a grand

ith a grand jury subpoena. The application is granted. I. Background A. The Protective Order In September 2015, commenced a civil suit against Ghislaine Maxwell, alleging that Maxwell had defamed by stating that was not the victim of sex crimes perpetrated by, among others, Maxwell and Jeffrey Eps

scovery, and (3) does not restrict the dissemination of the information if gained from other sources," it is not improvidently granted. Id (quoting Seattle Times Co. v. Rhinehart, 467 U.S. 20, 37 (1984)); see also FragranceNetcom, Inc. v. FragranceX.com, Inc., No. 06-cv-2225, 2010 WL 11606632, at *4 14 CONFIDEN