Epstein Secrets

RNOVICH, DBA CERNOVICH MEDIA Intervenors. ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, 15-CV-7433 (LAP) Ghislaine Maxwell's Opening Brief Ty Gee Adam Mueller HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Den r 2 Tel. Attorneys for Defendant-Appellant Ghisla

motion to unseal and the first appeal 6 The remand, the arrest, and the indictment. 7 The order unsealing the deposition material, including Ms. Maxwell's April 2016 deposition transcript 11 Events after the filing of the notice of appeal and the critical new information 13 Summary of the Argument

C. 150 East 10th Avenue Denver, CO 80203 Tel 303.831.7364 Fax 303.832.2628 [email protected] [email protected] Counsel for Defendant-Appellant Ghislaine Maxwell 42 EFTA00075524 Case 20-2413, Document 40, 08/20/2020, 2913550, Page49 of 74 Certificate of Compliance with Rule 32(A) This brief comp

rder unsealing the deposition material, including Ms. Maxwell's April 2016 deposition transcript 11 Events a

: [T]here is no question that the plain terms of the Maxwell Protective Order would justify such an expectati

, 08/20/2020, 2913550, Page5 of 74 Nixon a Warner Commc'ns, Inc., 435 U.S. 589 (1978) Nosik a Singe, 40 F.3d 592 (2d Cir. 1994) Press-Enter. Co. a Superior Ct., 464 U.S. 501 (1984) S.E.C. v. TheStreet.Com, 273 F.3d 222 (2d Cir. 2001) passim 34 37 passim Seattle Times Co. v. Rhinehart, 467 U.S. 20 (198

nd times, on August 27, 2003, Plaintiff Nelson Shanks provided notices to Defendants' counsel of the oral depositions of Defendants Jeffrey Epstein, Ghislaine Maxwell, Abigail Wexner and Leslie Wexner to be taken on September 9th and 10th, 2003 in the offices of Gollatz, Griffin & Ewing, P.C., in Philadelphia, Pa.

Page 2 of 7 Defendant ABIGAIL WEXNER H/W Defendant JEFFREY E. EPSTEIN INDIVIDUALLY doing business as J. EPSTEIN AND COMPANY, INC. Defendant GHISLAINE MAXWELL ATTORNEY TO BE NOTICED represented by CHRISTOPHER J. GUITON (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED J. FOX (See a

above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED Date Filed # Docket Text 10/02/2002 1 COMPLAINT against JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, ABIGAIL WEXNER, LESLIE WEXNER ( Filing fee $ 150 receipt number 803892.), filed by NELSON SHANICS.(ti, ) Additional attachment(s) added on 2/13/20

hereby move this Court, pursuant to Fed. R. Civ. P. 26(c)(2), for a protective order to reschedule and relocate the depositions of Jeffrey Epstein, Ghislaine Maxwell, and Abigail and Leslie Wexner, who received notices of oral deposition to be taken in the offices of Plaintiff's counsel, Gollatz, Griffin & Ewing

ia to the U.S. Virgin Islands for Mr. Epstein and Ms. Maxwell; and New Albany, Ohio for the Wexners. Accordin

would be better served if this matter were not litigated in this jurisdiction. See, e.g., Mesalic, 897 F.2d at 701 (citing Asahi Wild indua. Co. Superior Ct., 480 U.S. 102, 113, 107 &Ct. 1026, 94 L.Ed2d 92 (1987)). Accordingly, I find that this Court has general jurisdiction over the defendants and t

nited States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan, With the government's consent, the defendant has requested to file the parties' joint proposed juror question

k, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan, With the g

e New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan, Wi

om of the Press and the 17 undersigned news media organizations respectfully urge the Court to deny the defendant's request. Globe Newspaper Co. v. Superior Ct for Norfolk Cty., 457 U.S. 596, 609 n.25 (1982) (stating that "representatives of the press and general public must be given an opportunity to be h