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Cagean.g0c44/ 71SEAFierbd664164i igl5V2PilaW6M/Joagria44 1?)f 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Objections to Unsealing Docket Entries 143. 173. and 199 and to Unsealing Docket Entries 164
ia44 1?)f 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Objections to Unsealing Docket Entries 143. 173. and 199 and to Unsealing Docket Entries 164 and 230 at This Time. Laura A. Menninger Jeffrey S.
RGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 EFTA00075004 CageaUlg0caAIDer0dthhilfii igl5V2Pil&iA6/2bagctacir4 2%f 3 Defendant Ghislaine Maxwell, through her counsel and pursuant to this Court's Order and Protocol for Unsealing Decided Motions, DE 1044, as clarified by DE 1053, objects to the
supporting continued sealing/redaction of the item, and (c) whether the countervailing interests rebut the presumption of public access to the item. n. Maxwell, No. 15-CV-07433-LAP, 2020 WL 1547377, at *1 (S.D.N.Y. Mar. 31, 2020); DE 1044.' Based on the Court's clarification of its March 31, 2020 Order, DE
ISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Objections to Unsealing Docket Entries 143. 173
F.3d 772, 782 (3d Cir. 1994)). In that circuit if a document is filed with a court, it is a judicial document; otherwise it is not. See id. (citing Pansy, 23 F.3d at 782). The Amodeo I court cited two other Third Circuit cases confirming that circuit's litmus-test approach to identifying judicial doc
rt because Epstein killed himself last year in a federal lockup." According to the AP, "The claims by defense attorney Bobbi Sternheim were made on Ghislaine Maxwell's behalf after lawyers for the Metropolitan Detention Center warden in Brooklyn defended conditions at the facility in a Friday letter that was public
the Metropolitan Detention Center warden in Brooklyn defended conditions at the facility in a Friday letter that was publicly filed on Monday. 'Ms. Maxwell remains in good health,' the lawyers wrote in the letter as they defended her treatment as by-the-book following of rules to ensure the safety of al
ild Pandering Charges. • Attorneys Seek Bail For Ghislaine Maxwell. • FBI Seizes 40 Pounds Of Meth, Two Pou
riday letter that was publicly filed on Monday. 'Ms. Maxwell remains in good health,' the lawyers wrote in the
e advertising mini-dachsunds for sale and inquired about one of them, 'Pansy.' On March 11, she received a text from 'Hector Cantu' indicating that Pansy was still available for $600." The woman "ended up sending $9,100 in wire payments through Western Union," and "the whole thing was a fraud perpetra
ana Reservation. • FBI Joins Search For Missing Florida Teacher. • Ohio Firefighter Arrested On Child Pandering Charges. • Attorneys Seek Bail For Ghislaine Maxwell. • FBI Seizes 40 Pounds Of Meth, Two Pounds Of Heroin In New Mexico. • Resident Of State Of New York Sentenced To Decade In Prison For Selling Crac
part because Epstein killed himself last year in a federal lockup." According to the AP, "The claims by defense attorney Bobbi Stemheim were made on Ghislaine Maxwell's behalf after lawyers for the Metropolitan Detention Center warden in Brooklyn defended conditions at the facility in a Friday letter that
e Epstein killed himself last year in a federal lockup." According to the AP, "The claims by defense attorney Bobbi Stemheim were made on Ghislaine Maxwell's behalf after lawyers for the Metropolitan Detention Center warden in Brooklyn defended conditions at the facility in a Friday letter that was publ
Friday letter that was publicly filed on Monday. `Ms. Maxwell remains in good health,' the lawyers wrote in th
e advertising mini-dachsunds for sale and inquired about one of them, 'Pansy.' On March 11, she received a text from 'Hector Cantu' indicating that Pansy was still available for $600." The woman "ended up sending $9,100 in wire payments through Western Union," and "the whole thing was a fraud perpetra
rt because Epstein killed himself last year in a federal lockup." According to the AP, "The claims by defense attorney Bobbi Sternheim were made on Ghislaine Maxwell's behalf after lawyers for the Metropolitan Detention Center warden in Brooklyn defended conditions at the facility in a Friday letter that was publi
the Metropolitan Detention Center warden in Brooklyn defended conditions at the facility in a Friday letter that was publicly filed on Monday. `Ms. Maxwell remains in good health; the lawyers wrote in the letter as they defended her treatment as by-the-book following of rules to ensure the safety of al
ild Pandering Charges. • Attorneys Seek Bail For Ghislaine Maxwell. • FBI Seizes 40 Pounds Of Meth, Two Pou
riday letter that was publicly filed on Monday. `Ms. Maxwell remains in good health; the lawyers wrote in the
te advertising mini-dachsunds for sale and inquired about one of them, `Pansy: On March 11, she received a text from `Hector Cantu' indicating that Pansy was still available for $600." The woman "ended up sending $9,100 in wire payments through Western Union," and "the whole thing was a fraud perpetra
erbdthhiEgti id5i352PiletiViMdbagriad4 1?)f 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP \ Is. Maxwell's Objections to Unsealing Docket Entries 143, 173, and 199 and to Unsealing Docket Entries 164 and 2
Page: EFTA00022960 →TES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP \ Is. Maxwell's Objections to Unsealing Docket Entries 143, 173, and 199 and to Unsealing Docket Entries 164 and 230 at This Time. Laura A. Menninger Jeffrey S.
Page: EFTA00022960 →filegi i15§392PilgRiA6/2bagrt&j4 2%f 3 Defendant Ghislaine Maxwell, through her counsel and pursuant to this
Page: EFTA00022961 →re stated in her accompanying memorandum of law. Ms. Maxwell, does not object to the potential unsealing of th
Page: EFTA00022961 →ird Circuit's focus was "`on the technical question of whether a document is physically on file with the court."' Amodeo I, 44 F.3d at 145 (quoting Pansy v. Borough of Stroudsburg, 23 F.3d 772, 782 (3d Cir. 1994)). In that circuit if a document is filed with a court, it is a judicial document; otherwi
Page: EFTA00022972 →Entities connected to both Ghislaine Maxwell and Pansy

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATION
Donald Trump
PERSONJeffrey Pagliuca
PERSONLeon Black
PERSON
Eric Trump
PERSON
Julie K. Brown
PERSONLaura Menninger
PERSON
Virginia Giuffre
PERSONFBI
ORGANIZATION
Alison J. Nathan
PERSON
Denver
LOCATIONEmmy Taylor
PERSON
Joe Biden
PERSON
Prince Charles
PERSON
Samantha Power
PERSON
Stephen Hawking
PERSON
George Mitchell
PERSON