Epstein Secrets

nver, Colorado 80203 PH 303.831.7364 HI 303.832.2628 www.hmtlaw.com [email protected] 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

.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

eration of the Court's July 23 Ruling Giuffie v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Presk

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

l notice, as Judge Nathan herself may have, of the widespread negative media publicity and speculation directed at Mr. Epstein and Ms. Maxwell. See Condit v. Dunne, 317 F. Supp. 2d 344, 358 (S.D.N.Y. 2004). We attach a compilation of such articles in EXHIBIT E. The Court also may take judicial notice of Ms. Ma

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

l notice, as Judge Nathan herself may have, of the widespread negative media publicity and speculation directed at Mr. Epstein and Ms. Maxwell. See Condit v. Dunne, 317 F. Supp. 2d 344, 358 (S.D.N.Y. 2004). We attach a compilation of such articles in EXHIBIT E. The Court also may take judicial notice of Ms. Ma

ase 1:15-cv-07433-RWS Document 936 Filed 04/06/18 Page 1 of 21 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, - against - GHISLA1NE MAXWELL, Defendant. : Case No. 15-cv-7433 (RWS) MEMORANDUM OF LAW IN SUPPORT OF PROPOSED INTERVENORS JULIE BROWN AND MIAMI HERALD MEDIA COMPANY'S MOTIO

2 of 21 TABLE OF CONTENTS TABLE OF AUTHORITIES ii PRELIMINARY STATEMENT 1 I. INTERVENORS' COVERAGE OF ALLEGATIONS AGAINST JEFFREY EPSTEIN AND GHISLAINE MAXWELL 2 II. THE OVERBROAD SEALING ORDER AND PRIOR ATTEMPTS TO UNSEAL 3 III. THE ORDER DENYING THE MOTIONS TO UNSEAL 6 ARGUMENT 6 I. MIAM

ABLE OF CONTENTS TABLE OF AUTHORITIES ii PRELIMINARY STATEMENT 1 I. INTERVENORS' COVERAGE OF ALLEGATIONS AGAINST JEFFREY EPSTEIN AND GHISLAINE MAXWELL 2 II. THE OVERBROAD SEALING ORDER AND PRIOR ATTEMPTS TO UNSEAL 3 III. THE ORDER DENYING THE MOTIONS TO UNSEAL 6 ARGUMENT 6 I. MIAMI HERALD

. " or "Plaintiff') against Ghislaine Maxwell ("Ms. Maxwell" or "Defendant") on the grounds that Ms. Maxwell,

. Fishbein, 227 F.R.D. 239, 254 (S.D.N.Y. 2005) (movant must demonstrate good cause for order barring public dissemination of discovery materials); Condit v. Dunne, 225 F.R.D. 113, 115 (S.D.N.Y. 2004) (same). To show good cause under Rule 26(c), parties must demonstrate that disclosure will cause a clear and