Epstein Secrets

Cagean.g0c44/ 71SEAFierbd664164i igl5V2PilaW6M/Joagria44 1?)f 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Objections to Unsealing Docket Entries 143. 173. and 199 and to Unsealing Docket Entries 164

ia44 1?)f 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Objections to Unsealing Docket Entries 143. 173. and 199 and to Unsealing Docket Entries 164 and 230 at This Time. Laura A. Menninger Jeffrey S.

RGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 EFTA00075004 CageaUlg0caAIDer0dthhilfii igl5V2Pil&iA6/2bagctacir4 2%f 3 Defendant Ghislaine Maxwell, through her counsel and pursuant to this Court's Order and Protocol for Unsealing Decided Motions, DE 1044, as clarified by DE 1053, objects to the

supporting continued sealing/redaction of the item, and (c) whether the countervailing interests rebut the presumption of public access to the item. n. Maxwell, No. 15-CV-07433-LAP, 2020 WL 1547377, at *1 (S.D.N.Y. Mar. 31, 2020); DE 1044.' Based on the Court's clarification of its March 31, 2020 Order, DE

ISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Objections to Unsealing Docket Entries 143. 173

nce of Judge Frankel's decision in GAF Corp. v. Eastman Kodak Co., 415 F.Supp. 129 (S.D.N.Y.1976), with which I fully concur.") (footnote omitted). Martindeli was cited with approval in SEC v. TheStreet.com, 273 F.3d 222, 232 (2d Cir. 2001), which was cited with approval in Brown, 929 F.3d at 51 n.40. Not

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. : 20 Cr. 330 (MN) x MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION UNDER THE DUE PROCESS CLAUSE TO SUPPRESS ALL

OURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. : 20 Cr. 330 (MN) x MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION UNDER THE DUE PROCESS CLAUSE TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S SUBPOENA TO BOIES SCHILLER AND TO DI

ork, NY 10022 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00086658 TABLE OF CONTENTS TABLE OF CONTENTS TABLE OF AUTHORITIES ii TABLE OF EXHIBITS iv INTRODUCTION AND SUMMARY OF THE ARGUMENT 1 F

ury during two civil depositions conducted by Boies Schiller in a defamation action it filed against Maxwell on behalf of one of the firm's clients.M. Maxwell, Case No. 15-cv-7433 (LAP) (S.D.N.Y). A Protective Order entered in that case prohibited the parties and their lawyers from sharing confidential di

tor, did Boies Schiller have any role instigating the Maxwell inquiry. I EFTA00086663 To paraphrase Mary Mc

17 WL 2834260 (E.D. Pa. June 30, 2017) 17 Manhattan Review LLC v. Ytni, 16 Civ. 0102 (LAK) (JCF), 2017 WL 11455317 (S.D.N.Y. Sept. 21, 2017) 17 Martindeli v. Intl Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979) 12, 13 S.E.C. v. TheStreet.Com, 273 F.3d 222 (2d Cir. 2001) 12 Stewart v. Hudson Hall LLC

1651, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP the "A in connection with the matter v. Ghislaine Maxwell, et al. (a), (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A. Background As described in the Application, the Government has s

nformation simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). EFTA00084803 Page 4 Martindell, the district cour

simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). EFTA00084803 Page 4 Martindell, the district court opined

s the materials at issue here appear not to be of the sort that ordinarily would provide protection against Government investigation. See 3 To read Martindeli more broadly would not only be contrary to the opinion itself, as described above, but would risk rendering that opinion in even further conflict wi

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. : 20 Cr. 330 (MN) x MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION UNDER THE DUE PROCESS CLAUSE TO SUPPRESS ALL EVIDENCE

TABLE OF AUTHORITIES ii TABLE OF EXHIBITS iv INTRODUCTION AND SUMMARY OF THE ARGUMENT 1 FACTUAL BACKGROUND 2 A. The Protective Order in v. Maxwell 2 B. Maxwell's April and July 2016 depositions 4 C. The Settlement And Boies Schiller's Refusal To Comply With The Protective Order 6 D. The

17 WL 2834260 (E.D. Pa. June 30, 2017) 17 Manhattan Review LLC v. Ytni, 16 Civ. 0102 (LAK) (JCF), 2017 WL 11455317 (S.D.N.Y. Sept. 21, 2017) 17 Martindeli v. Intl Tel. & Tel. Cotp., 594 F.2d 291 (2d Cir. 1979) 12, 13 S.E.C. v. TheStreet.Com, 273 F.3d 222 (2d Cir. 2001) 12 Stewart v. Hudson Hall LLC

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. : 20 Cr. 330 (MN) x MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION UNDER THE DUE PROCESS CLAUSE TO SUPPRESS ALL EVIDENCE

TABLE OF AUTHORITIES ii TABLE OF EXHIBITS iv INTRODUCTION AND SUMMARY OF THE ARGUMENT 1 FACTUAL BACKGROUND 2 A. The Protective Order in v. Maxwell 2 B. Maxwell's April and July 2016 depositions 4 C. The Settlement And Boies Schiller's Refusal To Comply With The Protective Order 6 D. The

17 WL 2834260 (E.D. Pa. June 30, 2017) 17 Manhattan Review LLC v. Ytni, 16 Civ. 0102 (LAK) (JCF), 2017 WL 11455317 (S.D.N.Y. Sept. 21, 2017) 17 Martindeli v. Intl Tel. & Tel. Cotp., 594 F.2d 291 (2d Cir. 1979) 12, 13 S.E.C. v. TheStreet.Com, 273 F.3d 222 (2d Cir. 2001) 12 Stewart v. Hudson Hall LLC