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

a brief stay in order to seek relief in the Second Circuit. There is not a certain mechanism for doing that in an unsealing context but know that the Brown Court at the conclusion of their opinion stated their intent for that panel to maintain jurisdiction over this case for purposes of any appeals taken fro

IUD 1 2 3 4 UNITED STATES DISTRICT SOUTHERN DISTRICT OF COURT NEW YORK x Plaintiff, 5 v. 15 CV 7433 (LAP) 6 Remote Zoom Conference 7 GHISLAINE MAXWELL, 8 Defendant. x 9 New York, N.Y. 10 July 23, 2020 11:30 a.m. 11 Before: 12 HON. LORETTA A. PRESKA, 13 District Judge 14 APP

I make any mistakes in going over charts when we go document by document. To remind us where we are in the process of unsealing materials from v Maxwell, the Court is to: One, evaluate the weight of the presumption of public access to the materials; Two, identify and evaluate the weight of any cou

15 CV 7433 (LAP) 6 Remote Zoom Conference 7 GHISLAINE MAXWELL, 8 Defendant. x 9 New York, N.Y. 10 July

dged objections to unsealing. In her objections, Ms. Maxwell relies on several countervailing interests, the

a brief stay in order to seek relief in the Second Circuit. There is not a certain mechanism for doing that in an unsealing context but know that the Brown Court at the conclusion of their opinion stated their intent for that panel to maintain jurisdiction over this case for purposes of any appeals taken fro

L, Defendant. No. 15 Civ. 7433 (LAP) MEMORANDUM & ORDER LORETTA A. PRESKA, Senior United States District Judge: The Court has reviewed Defendant Ghislaine Maxwell's letter requesting reconsideration of the Court's July 23, 2020, decision to unseal (1) the transcripts of Ms. Maxwell's and Doe depositions, and (

pellant Ghislaine Maxwell EFTA00076383 Case 20-2413, Document 44, 08/20/2020, 2913556, Paget of 78 Docket Entries App.-0001 Order regarding Ms. Maxwell's Letter Motion to Reconsider July 23, 2020 Ruling, Dated July 29, 2020 (Dkt. 1079) App.-0777 Notice of Appeal, Dated July 29, 2020 (Dkt. 1081)

1432NARnetAltria &PO!, it, App.-0777 CEIRRI 85' RegEfaage7Sof 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, -against- GHISLAINE MAXWELL, Defendant. No. 15 Civ. 7433 (LAP) MEMORANDUM & ORDER LORETTA A. PRESKA, Senior United States District Judge: The Court has reviewed Def

of 78 Docket Entries App.-0001 Order regarding Ms. Maxwell's Letter Motion to Reconsider July 23, 2020 Rulin

brief stay in order to seek relief in the Second Circuit. There is not a certain mechanism for doing that in an unsealing context but I know that the Brown Court at the conclusion of their opinior stated their intent for that panel to maintain jurisdiction over this case for purposes of any appeals taken fro

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

put from the various Does, the lawyers for primarily Sigrid McCawley, a partner at BSF, and counsel for Ms. Maxwell. Judge Preska was obligated by the Brown Court first to identify what was or was not a "judicial document"; second, to determine the presumption of access to the document; and third, to identify