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,

wn v. Maxwell, 929 F.3d 41 (2d Cir. 2019) passim Dubose v. Pierce, 487 U.S. 1229 (1988) 15 Dubose v. Pierce, 761 F.2d 913 (2d Cir. 1985) 15 Gambale v. Deutsche Bank AG, 377 F.3d 133 (2d Cir. 2004) 16 Hilton v. Braunskill, 481 U.S. 770 (1987) 13 Hunt v. Enzo Biochem, Inc., 904 F. Supp. 2d 337 (S.D.N.Y. 2012)

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

a July 29, 2020 Page 2 courts have recognized, temporary stays of unseal orders are appropriate so that "[t]he genie is [not] out of the bottle," Gambale v. Deutsche Bank AG, 377 F.3d 133, 144 (2d Cir. 2004), before the interested parties have an opportunity to seek review of the orders. See, e.g., United Staten. Martom

EFTA00073262 Case 1:15-cv-07433-LAP Document 1111 Filed 09/01/20 Page 4 of 14 • (a) All currently sealed documents filed in support of Defendant Ghislaine Maxwell's motion for summary judgment (ECF No. 540 to 543, inclusive); • (b) All currently sealed documents filed in support of Plaintiff Virginia L. Giuffr

ruary 11, 2020). Access to other judicial documents in this action has already been granted to intervening private parties in interest, see Brown v. Maxwell, 929 F.3d 41 (2d Cir. 2019), and also is the subject of ongoing litigation before this Court. See, e.g., ECF No. 1096-1108. The 1 EFTA00073260 C

F NEW YORK Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-LAP

of access to certain judicial documents. Guzik v. Albright, No. 16-CV-2257 (JPO), 2018 U.S. Dist. LEXIS 196006, at *9 (S.D.N.Y. Nov. 16, 2018); see Gambale v. Deutsche Bank AG, 377 F.3d 133, 140 (2d Cir. 2004). The initial issue on a non-party's request for access to a document filed in a court is whether it is a "judicia

EFTA00077313 Case 1:15-cv-07433-LAP Document 1111 Filed 09/01/20 Page 4 of 14 • (a) All currently sealed documents filed in support of Defendant Ghislaine Maxwell's motion for summary judgment (ECF No. 540 to 543, inclusive); • (b) All currently sealed documents filed in support of Plaintiff opposition to Def

ruary 11, 2020). Access to other judicial documents in this action has already been granted to intervening private parties in interest, see Brown v. Maxwell, 929 F.3d 41 (2d Cir. 2019), and also is the subject of ongoing litigation before this Court. See, e.g., ECF No. 1096-1108. The EFTA00077311 Case

T SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-LAP

of access to certain judicial documents. Guzik v. Albright, No. 16-CV-2257 (JPO), 2018 U.S. Dist. LEXIS 196006, at *9 (S.D.N.Y. Nov. 16, 2018); see Gambale v. Deutsche Bank AG, 377 F.3d 133, 140 (2d Cir. 2004). The initial issue on a non-party's request for access to a document filed in a court is whether it is a "judicia

.D.N.Y. 2012) 11, 12 In re EPDM Antitrust Litt., 255 F.R.D. 308 (D. Conn. 2009) 12 Gambale v. Deutsche Bank AG, 377 F.3d 133 (2d Cir. 2004) v. Maxwell, No. 15 Civ. 7433, 2017 WL 1787934 (S.D.N.Y. May 3, 2017) 10, 11 10 Intl Equity Investments, Inc. v. Opportunity Equity Partners Ltd, No. 2010 W

THERN DISTRICT OF NEW YORK Plaintiff, —against— GHISLAINE MAXWELL, Defendant. 15 Civ. 7433 (RWS) MEMORANDUM OF L

THERN DISTRICT OF NEW YORK Plaintiff, —against— GHISLAINE MAXWELL, Defendant. 15 Civ. 7433 (RWS) MEMORAN

e Ins. Co. v. Electrolux Home Prods., Inc., 287 F.R.D. 130 (E.D.N.Y. 2012) 11, 12 In re EPDM Antitrust Litt., 255 F.R.D. 308 (D. Conn. 2009) 12 Gambale v. Deutsche Bank AG, 377 F.3d 133 (2d Cir. 2004) v. Maxwell, No. 15 Civ. 7433, 2017 WL 1787934 (S.D.N.Y. May 3, 2017) 10, 11 10 Intl Equity Investments, Inc. v. Op

bpoena. The application is granted. I. Background A. The Protective Order In September 2015, Virginia L. Giuffre commenced a civil suit against Ghislaine Maxwell, alleging that Maxwell had defamed Giuffre by stating that Giuffre was not the victim of sex crimes perpetrated by, among others, Maxwell a

e application is granted. I. Background A. The Protective Order In September 2015, Virginia L. Giuffre commenced a civil suit against Ghislaine Maxwell, alleging that Maxwell had defamed Giuffre by stating that Giuffre was not the victim of sex crimes perpetrated by, among others, Maxwell and Jeffre

tive order is a decision committed to the sound discretion of the trial court." TheStreet Com, 273 F.3d at 231 (internal quotation omitted); accord Gambale v. Deutsche Bank AG, 377 F.3d 133, 142 n.7 (2d Cir. 2004) ("If reliance would be unreasonable, it is within the discretion of the court to vacate or modify a protectiv

has filed an application for modification of a March 18, 2016 pretrial protective order, entered by the late Hon. in a civil defamation action, v. Maxwell, No. 15-cv-7433 (S.D.N.Y.) ("the Action"), in order to permit the law firm of Boles Schiller Flexner LLP ("Boies Schiller") to comply with a grand

ith a grand jury subpoena. The application is granted. I. Background A. The Protective Order In September 2015, commenced a civil suit against Ghislaine Maxwell, alleging that Maxwell had defamed by stating that was not the victim of sex crimes perpetrated by, among others, Maxwell and Jeffrey Eps

tive order is a decision committed to the sound discretion of the trial court." TheStreet.Com, 273 F.3d at 231 (internal quotation omitted); accord Gambale v. Deutsche Bank AG, 377 F.3d 133, 142 n.7 (2d Cir. 2004) ("If reliance would be unreasonable, it is within the discretion of the court to vacate or modify a protectiv