Epstein Secrets

.com [email protected] Re: Response to Government Letters dated May 4, and May 6, 2021 Regarding F.R. Crim. P. 17(c) Subpoena, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, On March 15, 2021, Ms. Maxwell asked the Court to issue a F.R.Crim.P. 17(c)(3) subpoena for production of evid

May 6, 2021 Regarding F.R. Crim. P. 17(c) Subpoena, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, On March 15, 2021, Ms. Maxwell asked the Court to issue a F.R.Crim.P. 17(c)(3) subpoena for production of evidence controlled by Boies, Schiller, and Flexner ("BSF") lawyers work

g F.R. Crim. P. 17(c) Subpoena, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, On

330 (MN) Dear Judge Nathan, On March 15, 2021, Ms. Maxwell asked the Court to issue a F.R.Crim.P. 17(c)(3)

ly misleading evidence." In re von Bulow, 828 F.2d 94, 102 (2d Cir. 1987); see also United States v. Bilzerian, 926 F.2d 1285, 1292 (2d Cir. 1991); Joy v. North, 692 F.2d 880, 893-94 (2d Cir. 1982); Teachers Ins. & Annuity Assin of America v. Shamrock Broadcasting Co., 521 F.Supp. 638 (S.D.N.Y. 1981). 2 As

ow precise. complete statement of relief sought: Order to Show Cause and March 13 Order should be reconsidered and vacated MOVING PARTY: Defendant Ghislaine Maxwell OPhintiff DDefendant ['Appellant/Petitioner nAppeUee/Respondent MOVING ATTORNEY: Ty Gee [name of attorney, with fm. Haddon, Morgan and Foreman

Case 18-2868, Document 141, 03/15/2019, 2519388, Page2 of 27 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-

ment 141, 03/15/2019, 2519388, Page4 of 27 has the ability to balance the public's interest in access to the discovery in court filings against Ms. Maxwell's and the non-parties' compelling interests. This is an extraordinary case. Ms. for more than a decade has actively pursued publicity and money fo

access to the discovery in court filings against Ms. Maxwell's and the non-parties' compelling interests. Thi

serve that interest.' ") (quoting Press-Enter. Co. a Superior Court of Cal. for Riverside Cny., 478 U.S. 1, 9 (1986); internal quotations altered); Joy v. North, 692 F.2d 880, 893 (2d Cir. 1982) (cited with approval in Lugosch and applying presumption of access to summary judgment 14 EFTA00791883 Case 18

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

l sought by the public or press, the material `should not remain under seal absent the most compelling reasons.'" Lugosch, 435 F.3d at 123 (quoting Joy v. North, 692 F.2d 880 (2d Cir. 1982)); Guzik v. Albright, No. 16-CV-2257 (JPO), 2018 U.S. Dist. LEXIS 196006, at *6-7 (S.D.N.Y. Nov. 16, 2018) (noting neit

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

l sought by the public or press, the material `should not remain under seal absent the most compelling reasons.'" Lugosch, 435 F.3d at 123 (quoting Joy v. North, 692 F.2d 880 (2d Cir. 1982)); Guzik v. Albright, No. 16-CV-2257 (JPO), 2018 U.S. Dist. LEXIS 196006, at *6-7 (S.D.N.Y. Nov. 16, 2018) (noting neit