Epstein Secrets

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

H A D D O N MORGAN FOREMAN August 17, 2020 VIA EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: Request to Mo

thern District of New York Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon,

H A D D O N MORGAN FOREMAN November 1, 2021 VIA EMAIL United States Attorney's Office Southern District of New York Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon, Morgan and Foreman, P.0 Jeffrey S. Paglitica PH Fx www.hmflaw.com Defendant Ghislaine Maxwell through

H A D D O N MORGAN FOREMAN November 1, 2021 VIA EMAIL United States Attorney's Office Southern District of New York Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon, Mo

cepted theory of grooming by third parties or empirical evidence regarding the prevalence, characteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed mi

acteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualiz

MORGAN FOREMAN March 8, 2021 VIA EMAIL United States Attorney's Office Southern District of New York New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Discovery request pertaining to FOIA productions Dear Counsel: I write to request certain discovery pursuant to Fed. R. Cr. P. 1

fuse to produce the records; the records have previously been released to a news media outlet, "relate to" the investigation and prosecution of Ms. Maxwell's alleged co-conspirator, and are in the government's "possession, custody, or control." We also request that your office detail when each batch of

"relate to" the investigation and prosecution of Ms. Maxwell's alleged co-conspirator, and are in the governm

HADDON MORGAN FOREMAN March 8, 2021 VIA EMAIL United States Attorney's Office Southern District of New York New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Discov

Office, and FBI Florida Office, regarding any other FOIA requests that have produced documents pertaining to any investigation of Jeffrey Epstein or Ghislaine Maxwell and produce to us the documents made public through the FOIA requests, the dates the documents were produced and the identity of the recipien

Menninger 150 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) Request to view physical evidence, "highly confidential" materials and scenes Dear Counsel: I write to formally request an opport

lege illegal conduct occurred, to include the Epstein properties for which you included photographs in the Superseding Indictment. Counsel for Ms. Maxwell and our investigator(s) are available for purposes of reviewing the physical evidence and Highly Confidential materials on March 17-18, 2021. Given

.com [email protected] Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Request to view physica

aphs in the Superseding Indictment. Counsel for Ms. Maxwell and our investigator(s) are available for purpose

H A D D O N MORGAN FOREMAN March 8, 2021 VIA EMAIL United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Haddon, Morgan and Foreman, r.0 Laura A.

st 10th Avenue Denver. Colorado 80203 www.hmffaw.com Re: Proposed Redactions to Request to Modify Protective Order (Under Seal) United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, In accordance with this Court's Order of August 18, 2020 (Doc. 44), Ms. Maxwell hereby respectfully submits un

al) United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, In accordance with this Court's Order of August 18, 2020 (Doc. 44), Ms. Maxwell hereby respectfully submits under seal her proposed redactions to her Request to Modify Protective Order ("Request"), filed under seal on August 17

y Protective Order (Under Seal) United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, In

this Court's Order of August 18, 2020 (Doc. 44), Ms. Maxwell hereby respectfully submits under seal her propo

Haddon, Morgan and Foreman. r.c Jeffrey Paglluca HADDON MORGAN FOREMAN pm August 24, 2020 VIA EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 150 East 10th Aven