Epstein Secrets

low precise, compkte statement of relief sought: Ms. Maxwell seeks a stay pending appeal, or in the alternati

& Kirk's intentions in requesting and obtaining the Maxwell materials from Boies Schiller, the Maxwell Protec

2413 Caption [use short till Motion for. Emergency Motion to Stay Pending Appeal Set forth below precise, compkte statement of relief sought: Ms. Maxwell seeks a stay pending appeal, or in the alternative, a temporary administrative stay to afford this Court sufficient time to consider on the merits

Plaintiff-Appellee, Defendant-Appellant, ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK 15-CV-7433 (LAP) Ghislaine Maxwell's Emergency Motion to Stay Pending Appeal or, in the Alternative, Motion for a Temporary Administrative Stay Pending Full Consideration of the Motion

. Respectfully submitted, s/ Adam Mueller Ty Gee Laura Menninger Adam Mueller HADDON, MORGAN AND FOREMAN, P.C. Counsel for Defendant-Appellant Ghislaine Maxwell 30 EFTA00074939 Case 20-2413, Document 10-1. 07/3012020. 2896538. Page38 of 38 Certificate of Service I certify that on July 30, 2020,

d the case to the district court to conduct a particularized review of the remaining records to which the Herald sought access. Id. at 53-54. Judge Pooler dissented in part. Id. at 54. Although she agreed the district court erred, she would only have unsealed the summary judgment order while leaving "

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

d the case to the district court to conduct a particularized review of the remaining records to which the Herald sought access. Id at 53-54. Judge Pooler dissented in part. Id at 54. Although she agreed the district court erred, she would have had this Court unseal only the summary judgment order whi

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

compelled—because of a strong expectation of continued confidentiality. See Fed. R. Civ. P. 5.2. While we appreciate the views expressed in Judge Pooler's separate opinion, the panel majority believes that the efforts invested by three former district judges in reviewing these materials adequately a

icated by disclosure of these materials. In the interests of judicial economy, any future appeal in this matter shall be referred to this panel. Pooler, Circuit Judge, dissenting in part: I join the Court's opinion in every respect but one: the decision to unseal the summary judgment record oursel

ow precise. complete statement of relief sought: Order to Show Cause and March 13 Order should be reconsidered and vacated MOVING PARTY: Defendant Ghislaine Maxwell OPhintiff DDefendant ['Appellant/Petitioner nAppeUee/Respondent MOVING ATTORNEY: Ty Gee [name of attorney, with fm. Haddon, Morgan and Foreman

Case 18-2868, Document 141, 03/15/2019, 2519388, Page2 of 27 IN THE UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT Plaintiff-Appellee, v. GHISLAINE MAXWELL, Defendant, v. SHARON CHURCHER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, Intervenors-Appellants No. 18-

ment 141, 03/15/2019, 2519388, Page4 of 27 has the ability to balance the public's interest in access to the discovery in court filings against Ms. Maxwell's and the non-parties' compelling interests. This is an extraordinary case. Ms. for more than a decade has actively pursued publicity and money fo

access to the discovery in court filings against Ms. Maxwell's and the non-parties' compelling interests. Thi

at "materials" in the Order to Show Cause means all the summary judgment filings. However, in her partial dissent to the Order to Show Cause, Judge Pooler refers to "the materials attached to the motion for summary judgment." Id. (emphasis supplied). 19 EFTA00791888 Case 18-2868, Document 141, 03/1

York, NY 10007 Tuesday, October 13, 2020, 2:00pm Panel: Cabranes, Pooler, Raggi, CM. Docket number Case name Time allotted 20-2413-cv (12) v. Ghislaine Maxwell Julie Brown, Miami Hearld Co., et al ] (12) 20-3061-cv United States of America ) v. Ghislaine Maxwell ) ) Time to be shared. EFTA00032483

me Time allotted 20-2413-cv (12) v. Ghislaine Maxwell Julie Brown, Miami Hearld Co., et al ] (12) 2

r Case name Time allotted 20-2413-cv (12) v. Ghislaine Maxwell Julie Brown, Miami Hearld Co., et al ]

0pm Venue Courtroom 1703 Thurgood Marshall US Courthouse 40 Foley Square New York, NY 10007 Tuesday, October 13, 2020, 2:00pm Panel: Cabranes, Pooler, Raggi, CM. Docket number Case name Time allotted 20-2413-cv (12) v. Ghislaine Maxwell Julie Brown, Miami Hearld Co., et al ] (12) 20-3061-

18-2868; 16-3945-cv(L) Brown v. Maxwell; Dershotvitz v. Giuffre 3n tlje Elute)) i§tateo Court of appeat55 for the i§ecortb Circuit AUGUST TERM 2018 No. 18-2868-cv JULIE BROWN, MIAMI H

tateo Court of appeat55 for the i§ecortb Circuit AUGUST TERM 2018 No. 18-2868-cv JULIE BROWN, MIAMI HERALD COMPANY, Intervenors-Appellants, v. GHISLAINE MAXWELL, Defendant-Appellee, v. VIRGINIA L. GIUFFRE, Plaintiff-Appellee. No. 16-3945-cv(L) No. 17-1625 (CON) No. 17-1722(CON) ALAN M. DERSHOW

ons. In response to the allegations, on January 3, 2015, Maxwell's publicist issued a press statement declaring that Giuffre's allegations "against Ghislaine Maxwell are untrue" and that her "claims are obvious lies. "6 B. Giuffre Sues Maxwell On September 21, 2015, Giuffre filed the underlying action against

record as described further herein, and REMAND the cause to the District Court for particularized review of the remaining sealed materials. Judge Pooler concurs in this opinion except insofar as it orders the immediate unsealing of the summary judgment record without a remand. SANFORD L. BOHRER (Ch

e to advise about possibility of denaturalization - First on A calendar; scheduled to start at 10:00 am (Cabranes, Pooler, Raggi) United States v. Maxwell arguing - Pre-trial appeal: whether district court's order denying D's motion to modify protective order is subject to interlocutory appeal; wheth

of counsel claim based on failure to advise about possibility of denaturalization - First on A calendar; scheduled to start at 10:00 am (Cabranes, Pooler, Raggi) United States v. Maxwell arguing - Pre-trial appeal: whether district court's order denying D's motion to modify protective order is subje