Epstein Secrets

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-

, P.C., submits this Response to the Court's Order to Show Cause ("OTSC"). I. Objections to the Order to Show Cause. For the reasons stated in Ms. Maxwell's Motion to Reconsider and Vacate the Court's Order to Show Cause and March 13 Order to Produce Sealed Materials, we respectfully object to the Cou

.C. 150 East 10th Avenue Denver, CO 80203 Tel 303.831.7364 [email protected]; [email protected]; [email protected] Attorneys for Defendant Ghislaine Maxwell 11 EFTA00794225 Certificate of Service I certify that on March 19, 2019, I served via CM/ECF a copy of this Appellee Maxwell's Response to Orde

e Order to Show Cause. For the reasons stated in Ms. Maxwell's Motion to Reconsider and Vacate the Court's Or

c disclosure of any sealed or redacted summary judgment materials. The OTSC is, however, incomplete because the dozens of individuals who relied on the Protective Order had no notice of the Order and have had no opportunity to respond. We interpose the following general objections: 1. All sealed and redacted summa

651, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP (the "A in connection with the matter v. Ghislaine Maxwell, et al. ("M"), 15 Civ. 7433 (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A. Background As described in the Application, the G

nformation simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). CONFIDENTIAL SDNY_GM_00000849 EFTA00066435 Page

simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). CONFIDENTIAL SDNY_GM_00000849 EFTA00066435 Page 4 Martin

proceeding such as in Subpoena Duces Tecwn—relied upon the Protective Order to indefinitely keep the relevant materials hidden. In this case, where the Protective Order is limited by its terms to only the pretrial stages of the civil litigation, no confidential business information appears to be at issue, and counse

1651, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP the "A in connection with the matter v. Ghislaine Maxwell, et al. (a), (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A. Background As described in the Application, the Government has s

nformation simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). EFTA00084803 Page 4 Martindell, the district cour

simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). EFTA00084803 Page 4 Martindell, the district court opined

proceeding such as in Subpoena Duces Tecwn—relied upon the Protective Order to indefinitely keep the relevant materials hidden. In this case, where the Protective Order is limited by its terms to only the pretrial stages of the civil litigation, no confidential business information appears to be at issue, and counse

51, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP (the "A in connection with the matter v. Ghislaine Maxwell, et at (a"), 15 Civ. 7433 (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A. Background As described in the Application, the Gov

nformation simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). CONFIDENTIAL SDNY_GM_00000849 EFTA_00114933 EFTA0

simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). CONFIDENTIAL SDNY_GM_00000849 EFTA_00114933 EFTA01263242

proceeding such as in Subpoena Duces Tecum-relied upon the Protective Order to indefinitely keep the relevant materials hidden. In this case, where the Protective Order is limited by its terms to only the pretrial stages of the civil litigation, no confidential business information appears to be at issue, and counse

2 of 7 United States District Court Southern District Of New York I DIME• ma z k a u c i 15-cv-07433-RWS Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant. X X PROTECTIVE ORDER Upon a showing of good cause in support of the entry of a protective order to protect the discovery and dissem

o all parties and an opportunity for them to be heard. 13Y THE STATES DISTRICT JUDGE 6 EFTA00793046 To: Laura Menninger, Esq. Re: Giuffre v. Maxwell, Case No. 1S-cv-07433 United States District Court For the Southern District of New York March 17, 2016 Protective Order by United States District

-07433-RWS Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant. X X PROTECTIVE ORDER Upo

that case.' Under the terms of the Protective Order, "Confidential" documents "shall not be disclosed or used for any purpose except the A copy of the Protective Order is attached hereto as Exhibit A. Out of respect for the provisions of the Protective Order, we are submitting this letter under seal. EFTA00793037

NFIDENTIAL" shall be information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ohislaine Maxwell. 4. CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial of this case. 5. CONFIDENTIAL docum

ct Of New York. ' • Plaintiff, v. Gh isla ine Maxwell, Defendant. X X I ~ tiikn -31_1S) PROTECTI

Case 1:15-cv-07433-RWS Document 39.1 Filed 03/02/16 Page 2 of 7 United States District Court Southern District Of New York. ' • Plaintiff, v. Gh isla ine Maxwell, Defendant. X X I ~ tiikn -31_1S) PROTECTIVE ORDER Upon a showing of good cause in support of the entry of a protective order to protect the

" Exhibit A at ¶ 4. Further, any documents marked "Confidential" must be returned or destroyed at the conclusion of the case. Id. at1 12. A copy of the Protective Order is attached hereto as Exhibit A. Out of respect for the provisions of the Protective Order, we are submitting this letter to the Court under seal.

("August 7 Letter"), regarding a) the briefing schedules for the defendants' motions i) seeking relief from a protective order issued in the Gee v. Maxwell matter ("Protective Order" and "Giuffre Matte?) and ii) to dismiss the plaintiff's First Amended Complaint ("FAC") in the above-captioned matter ("J

ter and the defendants' motion to dismiss the FAC. In fact, the July 17 Order does not set any deadline for submission of the motion for relief from the Protective Order; it only requires the parties to meet and confer before filing that motion — which the defendants attempted to do with Mr. Edwards. Moreover, the J

er ("August 7 Letter"), regarding a) the briefing schedules for the defendants' motions i) seeking relief from a protective order issued in the v. Maxwell matter ("Protective Order" and "M Matte?) and ii) to dismiss the plaintiff's First Amended Complaint ("FAC") in the above-captioned matter ("Jane D

ter and the defendants' motion to dismiss the FAC. In fact, the July 17 Order does not set any deadline for submission of the motion for relief from the Protective Order; it only requires the parties to meet and confer before filing that motion — which the defendants attempted to do with Mr. Edwards. Moreover, the J

d premature fishing expedition. As we previously advised the Court, the Plaintiff gave deposition testimony and documents in a matter captioned v. Maxwell, No. 15 Civ. 7433 (RWS) (the egio action") shortly after she filed this action (the "Plaintiff's Evidence"). The Plaintiff's Evidence was designate

ed for any deposition of Mr. Epstein. We respectfully submit that there is no reason to deviate from the July 17 Order. The motion for relief from the Protective Order has been submitted to Judge Sweet. Once Judge Sweet rules on the motion, Defendants will submit their Motion to Dismiss within seven (7) days. The

v. Maxwell, — F.Supp.3d — (2018) 2018 WL 4062649 Only the Westlaw citation is currently available. United States District Court, S.D. New York. Plaintiff,

F.Supp.3d — (2018) 2018 WL 4062649 Only the Westlaw citation is currently available. United States District Court, S.D. New York. Plaintiff, v. Ghislaine MAXWELL, Defendant. 15 Civ. 7433 i Signed 08/27/2018 Synopsis Background: Following settlement of plaintiff's action for defamation, news media and inv

s District Court, S.D. New York. Plaintiff, v. Ghislaine MAXWELL, Defendant. 15 Civ. 7433 i Signed 08/2

her claim of defamation by Maxwell arising out of the Maxwell January 3 Statement. alleged she was the "victim

mmon law right of access, or of the more robust First Amendment right to access certain judicial documents. Id. at 119-20. It is a given accepted by the Protective Order that the trial and all trial documents are accessible and public absent special circumstances. *8 1121 II3IUnder the common law approach, once a do