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

r. 1987) 37, 40 In re Teligent, Inc., 640 F.3d 53 (2d Cir. 2011) 1 Joy v. North, 692 F.2d 880 (2d Cir. 1982) 22 Louis Vuitton Malletier S.A. v. LY USA, Inc., 676 F.3d 83 (2d Cir. 2012) 34 Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) 19, 21 Maldanado v. City of New York, Case No. 17

n Support of Letter Motion to Stay Proceedings 20-cv-484 (JGK-DCF), Jane Doe v. Darren K. Indyke, et at Dear Judge Freeman: On behalf of defendant Ghislaine Maxwell, I write in further support of a Motion to Stay Proceedings in this matter until the conclusion of the criminal trial in United States v. Maxwell,

e Maxwell, I write in further support of a Motion to Stay Proceedings in this matter until the conclusion of the criminal trial in United States v. Maxwell, 20 Cr. 330 (AJN) ("Criminal Case"). Plaintiff apparently concedes, by failing to respond, that (a) she is one of the three accusers mentioned in t

t at Dear Judge Freeman: On behalf of defendant Ghislaine Maxwell, I write in further support of a Motion

nal Case to proceed first, and (e) absent a stay, Ms. Maxwell will be forced to choose between her constitutio

case simply because she has been indicted." Resp. at 6. The Second Circuit has a litany of factors, articulated in Louis Vuitton Malletier S.A. v. LY USA, Inc., 676 F.3d 83, 96 (2d Cir. 2012), and applied numerous times since. Plaintiff has not identified any case applying the Louis Vuitton factors in which

chard D. Kahn, & Ghislaine Maxwell, 19-10475-LGS-DCF Dear Judge Freeman: Pursuant to Individual Rule I.D, Plaintiff hereby responds to Defendant Ghislaine Maxwell's request for a pre-motion conference in connection with her anticipated motion to stay discovery in this matter. The Court should deny Maxwell's moti

aine Maxwell's request for a pre-motion conference in connection with her anticipated motion to stay discovery in this matter. The Court should deny Maxwell's motion for a pre-motion conference and deny her anticipated motion in its entirety because, as explained below, each of Maxwell's reasons for sta

18, 2020 v. Darren K. Indyke, Richard D. Kahn, & Ghislaine Maxwell, 19-10475-LGS-DCF Dear Judge Freeman:

ivil case to permit conclusion of a related criminal prosecution has been characterized as an extraordinary remedy." Louis Vuitton Malletier S.A. v. LY USA, Inc., 676 F.3d 83, 98 (2d Cir. 2012) (internal quotation marks omitted). In this Circuit, courts balance the following six factors when considering whet

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

gs when related criminal proceedings are imminent or pending, and it will sometimes be prudential to do so" (quoting Louis Vuitton Ma!leder S.A. v. LY USA, Inc., 676 F.3d 83, 98 (2d Cir. 2012))). Among other things, the stay vindicates the Fifth Amendment and guards against witnesses learning information in

ates Courthouse 500 Pearl Street New York, NY 10007 Re: Doe v. Indyke, et al., 1:20-cv-000484-JGK-DCF Plaintiff's Opposition Letter to Defendant Ghislaine Maxwell's Letter Motion to Stay Proceedings Dear Judge Freeman: On behalf of plaintiff Jane Doe in the above-referenced litigation, we hereby submit this

eferenced litigation, we hereby submit this opposition to defendant Ghislaine Maxwell's Motion to Stay. INTRODUCTION On August 19, 2020, defendant Maxwell wrote to this Court requesting that it stay this case until the conclusion of her pending criminal case in which she is accused of recruiting and e

K-DCF Plaintiff's Opposition Letter to Defendant Ghislaine Maxwell's Letter Motion to Stay Proceedings Dea

vil case to permit conclusion of a related criminal prosecution has been characterized as an "extraordinary remedy." Louis Vuitton Malletier S.A. v. LY USA, Inc., 676 F.3d 83, 98 (2d Cir. 2012) (emphasis added). As a result, a civil defendant urging a stay pending a parallel criminal prosecution bears the bu