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,

consider the merits of Ms. Maxwell's motion to stay pending appeal. Argument I. This Court should stay the district court's order pending appeal. Federal Rule of Appellate Procedure 8 governs a motion for a stay pending appeal. Fed. R. App. P. 8(a)(2). Under that Rule, this Court will stay a district court order pendi

ELL, Defendant. x THE GOVERNMENT'S MEMORANDUM IN SUPPORT OF DETENTION For the reasons set forth herein, the Government respectfully submits that Ghislaine Maxwell, the defendant, poses an extreme risk of flight; that she will not be able to rebut the statutory presumption that no condition or combination of co

v. GHISLAINE MAXWELL, Appellant. On Appeal from the United States District Court for the Southern District of New York, 20-CR-330 (MN) Appellant Ghislaine Maxwell's Motion for Pretrial Release David Oscar Markus MARKUS/MOSS PLLC 40 N.W. Third Street Penthouse One Miami, Florida 33128 EFTA00093045 Case 21-

3068296, Page2 of 31 No. 21-770 & 21-58 In the Mufti) Sates' Court of 5Appeats for the £ieconb (Circuit UNITED STATES OF AMERICA. Appellee, v. GHISLAINE MAXWELL, Appellant. On Appeal from the United States District Court for the Southern District of New York, 20-CR-330 (MN) Appellant Ghislaine Max

nimous that such conditions produce mental deterioration, which prevents her from effective participation in trial preparation. Worse, even if Ms. Maxwell were able to be fully alert and mentally acute, she must review over 2,500,000 prosecution pages on a gutted computer, which does not have the abil

rticipation in trial preparation. Worse, even if Ms. Maxwell were able to be fully alert and mentally acute,

R. APP. P. 27. According to Microsoft Word, the numbered pages of this petition contains 5,185 words, excluding the parts of the brief exempted by Federal Rule of Appellate Procedure 27(d)(2). This petition complies with the typeface requirements of Fed. R. App. P. 32(a)(5) and the type-style requirements of Fed. R. A

. GHISLAINE MAXWELL, Appellant. On Appeal from the United States District Court for the Southern District of New York, 20-CR-330 (AJN) Appellant Ghislaine Maxwell's Renewed Motion for Pretrial Release Leah S. Saffian David Oscar Markus LAW OFFICES OF LEAH SAFFIAN *Counsel of Record ME- markuslaw.com EFTA00

I2-13) EFTA00089451 No. 21-770 & 21-58 In the ZiRita) *tates Court of Apprat5 for the *mufti Circuit UNITED STATES OF AMERICA, Appellee, v. GHISLAINE MAXWELL, Appellant. On Appeal from the United States District Court for the Southern District of New York, 20-CR-330 (AJN) Appellant Ghislaine Ma

for bond (see Ex. A, Order, April 27, 2021), it appeared concerned with the conditions of her confinement during oral argument and instructed Ms. Maxwell that "[t]o the extent Appellant seeks relief specific to her sleeping conditions, such request should be addressed to the District Court." (Id.).

uld be addressed to the District Court." (Id.). Ms. Maxwell did just that, explaining again to the trial judg

R. APP. P. 27. According to Microsoft Word, the numbered pages of this petition contains 2,038 words, excluding the parts of the brief exempted by Federal Rule of Appellate Procedure 27(d)(2). This petition complies with the typeface requirements of Fed. R. App. P. 32(a)(5) and the type-style requirements of Fed. R. Ap

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT X UNITED STATES OF AMERICA Dkt. Nos. 21-58, 21-770 Appellee, GHISLAINE MAXWELL, Defendant-Appellant. x AFFIRMATION IN OPPOSITION TO DEFENDANT'S RENEWED MOTION FOR PRETRIAL RELEASE STATE OF NEW YORK COUNTY OF NEW

District of New York, and I represent the United States of America in this matter. I submit this affirmation in opposition to defendant-appellant Ghislaine Maxwell's renewed motion for pretrial release following this Court's order, dated April 27, 2021, which denied Maxwell's prior motion for bail or temporary p

tion to defendant-appellant Ghislaine Maxwell's renewed motion for pretrial release following this Court's order, dated April 27, 2021, which denied Maxwell's prior motion for bail or temporary pretrial release and affirmed the District Court's orders denying such relief. EFTA00091595 PRELIMINARY STA

dge Nathan asking the District Court "to address Ms. Maxwell's sleeping conditions by directing the MDC to cea

, New York May 27, 2021 Assistant United States Attorneys Southern District of New York 23 EFTA00091617 CERTIFICATE OF COMPLIANCE Pursuant to Federal Rule of Appellate Procedure 32(g), the undersigned counsel hereby certifies that this opposition complies with the type-volume limitation of the Federal Rules of App

20-2413-cv United States Court of Appeals for the Second Circuit VIRGINIA L GIUFFRE, —against- GHISLAINE MAXWELL, Plaintiff-Appellee, Defendant-Appellant. ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK 15-CV-74

s with the Government's position and opposes Defendant's motion to consolidate this appeal (the "civil appeal") with her appeal in United States v. Maxwell, No. 20-3061 (the "criminal appeal"). To the extent that Defendant's criminal appeal is not dismissed, Defendant's motion to consolidate should be

to one another. First, the issues presented in the criminal appeal have no bearing on the civil Citations to "D.E." refer to this Court's docket. Ghislaine Maxwell's Appendix is cited as "App." Virginia Giuffre's Supplemental Appendix is cited as "SA." EFTA00095336 appeal, and vice versa. As the Government's l

oad arguments lacking in specificity. App. 777 ("Ms. Maxwell's eleventh-hour request for reconsideration is de

ley Boies Schiller Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale FL 33301 6 EFTA00095341 Certificate of Compliance Pursuant to Federal Rule of Appellate Procedure 32(g), the undersigned counsel hereby certifies that this response complies with the type-volume limitation of the Federal Rules of Appel

. GHISLAINE MAXWELL, Appellant. On Appeal from the United States District Court for the Southern District of New York, 20-CR-330 (AJN) Appellant Ghislaine Maxwell's Renewed Motion for Pretrial Release Leah S. Saffian LAW OFFICES OF LEAH SAFFIAN 15546 Meadowgate Road Encino, California 91436-3429 Tel: (858)4

21, 3102450, Paget of 14 No. 21-770 & 21-58 In the Malta *tates Court of Appeat5 for the *tomb Circuit UNITED STATES OF AMERICA, Appellee, v. GHISLAINE MAXWELL, Appellant. On Appeal from the United States District Court for the Southern District of New York, 20-CR-330 (AJN) Appellant Ghislaine Ma

for bond (see Ex. A, Order, April 27, 2021), it appeared concerned with the conditions of her confinement during oral argument and instructed Ms. Maxwell that "[t]o the extent Appellant seeks relief specific to her sleeping conditions, such request should be addressed to the District Court." (Id.).

uld be addressed to the District Court." (Id.). Ms. Maxwell did just that, explaining again to the trial judg

R. APP. P. 27. According to Microsoft Word, the numbered pages of this petition contains 2,038 words, excluding the parts of the brief exempted by Federal Rule of Appellate Procedure 27(d)(2). This petition complies with the typeface requirements of Fed. R. App. P. 32(a)(5) and the type-style requirements of Fed. R. Ap

ING ATTORNEY: Kerrie L. Campbell [name of attorney, whh firm, address. glione number and e-mail] KCampbell-Law, PLLC BOIES SCHILLER FLEXNER UP v. Maxwell OPPOSING ATTORNEY:Sigrid moe-awieY 1629 K St., NW, Suite 300, Washington, DC 20006 401 E. Las Olas Blvd. Suite 1200 Fort Lauderdale, FL, 33301 2

co-counsel with: (name/firm) Defendant-Appellee Ghislaine Maxwell IZIAmicus (in support of: (party/designation)

co-counsel with: (name/firm) Defendant-Appellee Ghislaine Maxwell IZIAmicus (in support of: (party/design

ROWN, MIAMI HERALD MEDIA COMPANY, Intervenors-Appellants. EFTA00792258 Case 18-2868, Document 153-1, 03/19/2019, 2521600, Page4 of 6 Pursuant to Federal Rule of Appellate Procedure 29(a)(3) and Second Circuit Local Rule 29.1(b), John Doe respectfully requests leave of this Court to file the attached brief as amicus c