Epstein Secrets

MAXWELL JEFFREY EPSTEIN, PRINCE ANDREW, 3/22/20 EFTA00075107 Casgastetal14331atitilmetbdOnttit7187.82412CF 057g9/28gEFEeigef 6208161 Socialite Ghislaine Maxwell 'groped a 16-year-old girl during a naked massage,' victims' lawyer says El dailvmail.co.ukThews/article-8163681/Socialite-Ghislaine-Maxwell-qroped-1

.com Re: Reconsideration of the Court's July 23 Ruling Giuffie v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its Protective Order and punish its violation. Ms. Maxwell's two deposition transcripts were designated

rated for Jeffrey Epstein's personal sexual satisfaction. So to the degree that um there was a main facilitator that started the whole thing, it was Ghislaine. 3 A purported transcript of the press conference is contained on the intemet at https://www.rev.comiblog,/transcripts/announcement-transcript-of-c

v. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its

ining the Maxwell materials from Boies Schiller, the Maxwell Protective Order explicitly provides that (1) di

otential witnesses; h. any person (1) who authored or received the particular Protected Material; (2) who has or had at any point in time access to the Protected Material outside of the context of this action; or (3) for which there is a good faith basis to conclude that the individual has earlier received or seen su

TO: Laura Menninger, Esq. Haddon, Morgan and Foreman, P.C. Fax No. Telephone No. FROM: Sigrid S. McCawley, Esq. DATE: February 26, 2016 RE: r. Maxwell, Case no. 15-cv-07433-RWS Total Number of Pages: 26 (including this cover sheet) MESSAGE: Attached please find a copy of my email transmission

1:15-cv-07433-LAP Document 1078-4 Filed 07/29/20 Page 3 of 1010019/0026 United States District Court Southern District Of New York Plaintiff, v. Ghislaine Maxwell, Defendant. 15-cv-07433-RWS AGREED PROTECTIVE ORDER Upon a showing of good cause in support of the entry of a protective order to protect the di

McCawley, Esq. DATE: February 26, 2016 RE: r. Maxwell, Case no. 15-cv-07433-RWS Total Number of Pages

t Southern District Of New York Plaintiff, v. Ghislaine Maxwell, Defendant. 15-cv-07433-RWS AGREED PRO

otential witnesses; h. any person (1) who authored or received the particular Protected Material; (2) who has or had at any point in time access to the Protected Material outside of the context of this action; or (3) for which there is a good faith basis to conclude that the individual has earlier received or seen su

:15-cv-07433-RWS Document 41-5 Filed 03/04/16 Page 2 of 18 United States District Court Southern District Of New York Plaintiff, I5-cv-07433-RWS Chislaine Maxwell, Defendant. JPROPOSEDI PROTECTIVE ORDER Upon a showing of good cause in support of the entry of a protective order to protect the discovery and d

3-RWS Document 41 Filed 03/04/16 Page 1 of 4 United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF PLAINTIFF'S RESPONSE TO DEFENDANT'S MOTION FOR PROTECTIVE ORDER I, Sigrid S. McCawley

intiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. DECLARATION OF SIGRID S. McCAWLEY I

York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. DECLARATION OF SIGRID S. Mc

tial witnesses; and h. any person (1) who authored or received the particular Protected Material: (2) who has or had at any point in time access to the Protected Material outside of the context of this action: or (3) for which there is a good faith basis to conclude that the individual has earlier received or seen su

Laura Menninger, Esq. Haddon, Morgan and Foreman, P.C. Fax No. Telephone No. FROM: Sigrid S. McCawley, Esq. DATE: February 26, 2016 RE: .r . Maxwell, Case no. 15-cv-07433-RWS Total Number of Pages: 26 (including this cover sheet) MESSAGE: Attached please find a copy of my email transmission

:15-cv-07433-LAP Document 1078-4 Filed 07/29/20 Page 3 of 1010019/0026 United States District Court Southern District Of New York Plaintiff, v. Ghislaine Maxwell, Defendant. 15-cv-07433-RWS AGREED PROTECTIVE ORDER Upon a showing of good cause in support of the entry of a protective order to protect the di

t Southern District Of New York Plaintiff, v. Ghislaine Maxwell, Defendant. 15-cv-07433-RWS AGREED PRO

otential witnesses; h. any person (1) who authored or received the particular Protected Material; (2) who has or had at any point in time access to the Protected Material outside of the context of this action; or (3) for which there is a good faith basis to conclude that the individual has earlier received or seen su