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

Case 20-2413. Document 40. 08'20/2020. 2913550, Pagel of 74 20-2413 United States Court of Appeals for the Second Circuit Plaintlff-Appelke, —against— GHISLA1NE MAXWELL, Defendant-Appellant, SHARON CHURCHER, JEFFREY EPSTEIN, Respondents, JUL

Nos. 20-2413 & 20-3061 United States Court of Appeals for the Second Circuit Plaintiff-Appellee, v. GHISLAINE MAXWELL, Defendant- Appellant. UNITED STATES OF AMERICA, PlaintificAppellee, v. GHISLAINE MAXWELL, Defendant-Appellant. On Appeal from the U.S

peal from the U.S. District Court for the Southern District of New York No. 20-CR-330 (AJN) The Honorable Alison J. Nathan, U.S. District Judge Ghislaine Maxwell's Response to Opposition to Motion to Consolidate EFTA00079364 The government and insist this case and the criminal case are unrelated. But that's

ate EFTA00079364 The government and insist this case and the criminal case are unrelated. But that's not so. The criminal case alleges that Ms. Maxwell committed perjury in the civil case. Two of the six counts are expressly based on the civil case. Moreover, the discovery in the criminal case incl

ut that's not so. The criminal case alleges that Ms. Maxwell committed perjury in the civil case. Two of the

Nos. 20-2413 & 20-3061 United States Court of Appeals for the Second Circuit Plaintiff-Appellee, v. GHISLAINE MAXWELL, Defendant- Appellant. UNITED STATES OF AMERICA, PlaintificAppellee, v. GHIS

20-2413-cv United States Court of Appeals for the Second Circuit VIRGINIA L GIUFFRE, —against- GHISLAINE MAXWELL, Plaintiff-Appellee, Defendant-Appellant. ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK 15-CV-74

s with the Government's position and opposes Defendant's motion to consolidate this appeal (the "civil appeal") with her appeal in United States v. Maxwell, No. 20-3061 (the "criminal appeal"). To the extent that Defendant's criminal appeal is not dismissed, Defendant's motion to consolidate should be

to one another. First, the issues presented in the criminal appeal have no bearing on the civil Citations to "D.E." refer to this Court's docket. Ghislaine Maxwell's Appendix is cited as "App." Virginia Giuffre's Supplemental Appendix is cited as "SA." EFTA00095336 appeal, and vice versa. As the Government's l

oad arguments lacking in specificity. App. 777 ("Ms. Maxwell's eleventh-hour request for reconsideration is de

20-2413-cv United States Court of Appeals for the Second Circuit VIRGINIA L GIUFFRE, —against- GHISLAINE MAXWELL, Plaintiff-Appellee, Defendant-Appellant. ON APPEAL FROM THE UNITED STAT

erning Use of Discovery Materials GM_00000847-962 Dear Mr. ell is actively litigating issues related to disclosure of confidential material in v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) and a related appeal in the United States Court of Appeals for the Second Circuit, 20-2413. We intend to ask Judge Nathan f

e to the Government's efforts to obtain civil litigation discovery material ("the Unsealing Materials") in two, settled, civil matters in which Ms. Maxwell was named a defendant. These materials would be disclosed to Judge Preska and designated as part of the appendix to Ms. Maxwell's appeal in the Sec

ed to disclosure of confidential material in v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) and a related app

erials") in two, settled, civil matters in which Ms. Maxwell was named a defendant. These materials would be

ively litigating issues related to disclosure of confidential material in v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) and a related appeal in the United States Court of Appeals for the Second Circuit, 20-2413. We intend to ask Judge Nathan for permission to refer to and attach, as exhibits, the above referenced discovery m

Brown v. Maxwell, — F.3d — (2019) 2019 WL 2814839 Only the Westlaw citation is currently available. United States Court of Appeals, Second Circuit. Julie BROWN,

citation is currently available. United States Court of Appeals, Second Circuit. Julie BROWN, Miami Herald Company, Intervenors-Appellants, v. Ghislaine MAXWELL, Defendant-Appellee, v. MM. Plaintiff-Appellee. . r owitz, Michael Cernovich, dba Cernovich Media, Intervenors-Appellants, v. Plaintiff-App

ating accusations. In response to the allegations, on January 3, 2015, Maxwell's publiSid a press statement declaring that allegations "against Ghislaine Maxwell are untrue" and that her "claims are obvious lies."6 6 SeMIEv. Maxwell, 325 F. Supp. 3d 428, 434 (S.D.N.Y. 2018). BM Sues Maxwell On

Brown v. Maxwell, — F.3d — (2019) 2019 WL 2814839 Only the Westlaw citation is currently available. United States Court of Appeals, Second Circuit. Julie BROWN, Miami Herald Company, Intervenors-Appellants, v. Ghislaine MAXWELL, Defendant-Appellee, v. MM. Plaintiff-Appel

ip to Epstein. Little is known about Epstein except that his offices are in the landmarked Villard House across from Le Cirque, and he once employed Ghislaine Maxwell, daughter of the late British press lord Robert Maxwell, in an unspecified capacity. But Tucker is playing America's first black president in "Mr.

t Side dinners," the woman recalls. "Many seemed foreign and dressed a little bizarrely." This same guest also at- tended a cocktail party thrown by Maxwell that Prince Andrew attended, which was filled, she says, with young Russian models. "Some of the guests were horri- fied," the woman says. "He's re

ouse across from Le Cirque, and he once employed Ghislaine Maxwell, daughter of the late British press lord

chapter 13 plan is reinstated. REVERSED. UNITED STATES of America, Plaintiff-Appellant, I Jerry Lee HARVEY, Defendant-Appellee. No. 874051. United States Court of Appeals, Eleventh Circuit. April 14, 1989. Order dismissing indictment charging defendant with tax evasion and filing false 4. This statement, of course

uit Thurgood Marshall U.S. Courthouse New York, NY 10007 ROBERT A. KATZMANN CHIEFJUDGE Date: July 18, 2017 Docket #: 16-3945cv Short Title: v. Maxwell CLERK OF COURT DC Docket #: 15-cv-7433 DC Court: SDNY (NEW YORK CITY) DC Judge: Sweet NOTICE OF CASE MANAGER CHANGE The case manager assigned

Case 16-3945, Document 56, 07/18/2017, 2081160, Pagel of 1 United States Court of Appeals for the Second Circuit Thurgood Marshall U.S. Courthouse New York, NY 10007 ROBERT A. KATZMANN CHIEFJUDGE Date: July 18, 2017 Docket #: 16-3945c

ed arguments that purely intrastate conduct could not be prosecuted under the federal Child Pornography Prevention Act of 1996 ("CPPA"). First, in Maxwell, we held that 18 U.S.C. § 2252A(a)(5)(B) was not unconstitutional as applied to a defen- dant's intrastate possession of child por- nography, even

which at times seems to be forgotten." LIZZA AND SONS, INC., Plaintiff, Appellant, Daniel A. D'ONFRO et al., Defendants, Appellees. No. 5571. United States Court of Appeals First Circuit. Aug. 18, 1960. Action by general contractor against contractor and surety for breach of al- leged subcontract. The United States