Epstein Secrets

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

circumstances militating for or against a finding of timeliness.' D'Amato v. Deutsche Bank, 236 F.3d 78, 84 (2d Cir. 2001) (quoting United States v. Pitney Bowes, Inc., 25 F.3d 66, 70 (2d Cir. 1994)). The interest asserted must be "'direct, substantial, and legally protectable"' and not "'speculative or remo

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

circumstances militating for or against a finding of timeliness.' D'Amato v. Deutsche Bank, 236 F.3d 78, 84 (2d Cir. 2001) (quoting United States v. Pitney Bowes, Inc., 25 F.3d 66, 70 (2d Cir. 1994)). The interest asserted must be "'direct, substantial, and legally protectable"' and not "'speculative or remo

is life, mostly young, but there is no one of them to whom he has been able to commit. He describes his most public companion of the last decade, Ghislaine Maxwell. 41. the daughter of the late, disgraced media baron Robert Max- well, as simply his -best friend." He says she is not on his payroll, but she seem

Side dinners." the woman recalls. "Many seemed foreign and dressed a little bizarrely." This same guest also at- tended a cocktail party thrown by Maxwell that Prince Andrew attended, which was filled, she says. with young Russian mod- els. "Some of the guests were horrified," the woman says. "He's

n Ghislaine Maxwell, daughter of the fat and fraudulent former owner of the Daily News, the late Robert Maxwell. I hear that some of the 39-year-old Ghislaine's friends on the Manhattan and London party circuit are cutting her because she's had so much adverse press over her relationship with Prince Andre

Goldman, Sachs & Co.; former President, Federal Reserve Bank of New York Alain Cotta, Professor, University of Paris Michael 3 Critelli, Chairman, Pitney Bowes, Inc., Stamford Lester Crystal, NBC/RCA Gerald L. Curtis, Prof. Poli Sci, Columbia Univ. Kenneth Dam, U.S. Deputy Secretary of the Treasury Lynn