Epstein Secrets

ited States District Court Southern District of New York Re: Reply in Support of Request to Modify Protective Order (Under Seal)i United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, Defendant Ghislaine Maxwell filed a simple request: that she be permitted to disclose under seal to the Second

ernment touts its production of "more than 165,000 pages of discovery to the defense," of which (they neglect to mention), nearly 90,000 of the Ms. Maxwell has filed a letter motion which seeks leave to file this reply under seal, while providing the unredacted version to the government and the Court. T

y Protective Order (Under Seal)i United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, Def

(they neglect to mention), nearly 90,000 of the Ms. Maxwell has filed a letter motion which seeks leave to fi

24, 2020 Page 6 documents, that is, documents that are `relevant to the performance of the judicial function and useful in the judicial process.'" Kerik, 2014 WL 12710346, at *1 (S.D.N.Y. July 23, 2014), (quoting United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995)). The Materials that Ms. Maxwe

ational Outcry OTHER FBI NEWS • Roger Stone Says FBI is Acting Like Biden's 'Personal Gestapo' • Could These Epstein Insiders Bring Down Ghislaine Maxwell? • Despite Biden Vow, Afghanistan Evacuees Admitted to U.S. Underwent Almost No Vetting • Arbery, Rittenhouse Cases Spotlight Self-Defense, and Vig

reported on the story. Could These Epstein Insiders Bring Down Ghislaine Maxwell? The Daily Beast (11/28, Briquelet) reported that British heiress Ghislaine Maxwell will stand trial Monday on charges she procured girls for Jeffrey Epstein's underage sex ring, more than a year after her arrest at a luxury hideou

stapo' • Could These Epstein Insiders Bring Down Ghislaine Maxwell? • Despite Biden Vow, Afghanistan Evacue

subpoena for testimony issued by the congressional select committee investigating the Jan. 6 attack on the U.S. Capitol. According to the article, Kerik may use the demand for information as a publicity stunt. The article noted that the twice impeached president said the recently pardoned Trump loyal

Examiner (11/24, King) reported that the House committee investigating the Jan. 6 Capitol riot reportedly made a false accusation against a witness, Bernard Kerik, who worked for former President Donald Trump's attorney Rudy Giuliani to investigate the 2020 election. According to the article, the committee acc

2Tfir3N33(IDACIDMEEDdillibiligQ911031200309101528% ef15of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY FILED noC 0: un rr. FILED: 9/2/20 20-CR-330 (MN) MEMORANDUM OPINION AND ORDER ALISON J. NATHA

OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY

DISTRICT OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTR

6453344, at *2 (D. Conn. Dec. I, 2017) (applying the civil standard for the modification of a protective order in a criminal case); United States v. Kerik, No. 07-CR-1027 (LAP), 2014 WL 12710346 at *I (S.D.N.Y. July 23, 2014) (same). See also United States v. Morales, 807 F.3d 717, 723 (5th Cir. 2015)

ase 1:20-cr-00330-AJN Document 51 Filed 09/02/20 Page 1 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY FILED noC *: Dn FF. FILED: 9/2/20 20-CR-330 (AJN) MEMORANDUM OPINION AND ORDER ALISON J. NATH

OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY

DISTRICT OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTR

6453344, at •2 (D. Conn. Dec. I, 2017) (applying the civil standard for the modification of a protective order in a criminal case); United States v. Kerik, No. 07-CR-1027 (LAP), 2014 WL 12710346 at *I (S.D.N.Y. July 23, 2014) (same). See also United States v. Morales, 807 F.3d 717, 723 (5th Cir. 2015)

e persistence of Specialist Guillen's family also has kept front and center a case that might otherwise have left them in grief-stricken retreat." Maxwell's Lawyers Request She Be Released. The New York Times (7/10, Hong, Weiser, 18.61M) reports, "Lawyers for Ghislaine Maxwell, the longtime companion

t them in grief-stricken retreat." Maxwell's Lawyers Request She Be Released. The New York Times (7/10, Hong, Weiser, 18.61M) reports, "Lawyers for Ghislaine Maxwell, the longtime companion of Jeffrey Epstein, sought to distance her from the disgraced financier on Thursday, saying in a new court filing that the

7/10, Hong, Weiser, 18.61M) reports, "Lawyers for Ghislaine Maxwell, the longtime companion of Jeffrey Epste

inate number of them which have gone to people with either personal or political ties to Trump (or both): Joe Arpaio, Dinesh D'Souza, Conrad Black, Bernard Kerik, Rod Blagojevich, Michael Milken, Paul Pogue, David Safavian, Eddie DeBartolo Jr. and now Stone. It's hardly unheard-of for a president to pardon a

ound the bare waist of , then 17, who claims she was later paid by Jeffrey Epstein for sexual encounters with the prince. In the background stands Ghislaine Maxwell, a British socialite _ Page 12930 EFTA00043441 wno accusers say was Lipstein s ginmena ana maaam. i ne photo was reportedly taken at Maxwell's

ne Maxwell, a British socialite _ Page 12930 EFTA00043441 wno accusers say was Lipstein s ginmena ana maaam. i ne photo was reportedly taken at Maxwell's London home in 2001. ... With Epstein now dead after a suspected suicide Saturday and Maxwell apparently outside the reach of investigators, hid

unters with the prince. In the background stands Ghislaine Maxwell, a British socialite _ Page 12930 EFTA

he president ... Trump adviser and former New York City Mayor Rudy Giuliani also made it clear to Trump that Blagojevich's sentence was too harsh. Bernard Kerik, a former NYPD commissioner who served time in prison on a tax fraud conviction and has been advocating for Blagojevich, slammed the opposition."

und the bare waist of , then 17, who claims she was later paid by Jeffrey Epstein for sexual encounters with the prince. In the background stands Ghislaine Maxwell, a British socialite who accusers say was Epstein's girlfriend and madam. The photo was reportedly taken at Maxwell's London home in 2001. ... With

he background stands Ghislaine Maxwell, a British socialite who accusers say was Epstein's girlfriend and madam. The photo was reportedly taken at Maxwell's London home in 2001. ... With Epstein now dead after a suspected suicide Saturday and Maxwell apparently outside the reach of investigators, hidi

unters with the prince. In the background stands Ghislaine Maxwell, a British socialite who accusers say wa

the president ... Trump adviser and former New York City Mayor Rudy Giuliani also made it clear to Trump that Blagojevich's sentence was too harsh. Bernard Kerik, a former NYPD commissioner who served time in prison on a tax fraud conviction and has been advocating for Blagojevich, slammed the opposition."

ase 1:20-cr-00330-AJN Document 51 Filed 09/02/20 Page 1 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 9/2/20 20-CR-330 (MN) MEMORANDUM OPINION AND ORDER ALISON J. NATHAN,

OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY

DISTRICT OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTR

6453344, at •2 (D. Conn. Dec. I, 2017) (applying the civil standard for the modification of a protective order in a criminal case); United States v. Kerik, No. 07-CR-1027 (LAP), 2014 WL 12710346 at *I (S.D.N.Y. July 23, 2014) (same). See also United States v. Morales, 807 F.3d 717, 723 (5th Cir. 2015)

as212-6r310193MACINnEEIVANN95202QIERVON0:37217a Fab efi5of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC DATE FILED: 9/2/20 20-CR-330 (AJN) MEMORANDUM OPINION AND ORDER ALISON J. NATHAN,

OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY

DISTRICT OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTR

6453344, at *2 (D. Conn. Dec. I, 2017) (applying the civil standard for the modification of a protective order in a criminal case); United States v. Kerik, No. 07-CR-1027 (LAP), 2014 WL 12710346 at *I (S.D.N.Y. July 23, 2014) (same). See also United States v. Morales, 807 F.3d 717, 723 (5th Cir. 2015)