Epstein Secrets

aMbesf1laf 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK -against- ALAN DERSHOWITZ, Plaintiff, Defendant. Plaintiff, -against- GHISLAINE MAXWELL, Defendant. No. 19 Civ. 3377 (LAP) No. 15 Civ. 7433 (LAP) MEMORANDUM & ORDER LORETTA A. PRESKA, Senior United States District Judge: Be

tive Order.° All of those materials and any material, including work product, derived from the Maxwell materials (other than the deposition ofl in Maxwells) shall be destroyed. Counsel shall submit an affidavit detailing the steps taken to do so. Furthermore, to the extent that it is doing so, Cooper &

materials produced in discovery that "are confidential" and that implicate "common law and statutory privacy interests" of and Maxwell Defendant Ghislaine Maxwell ("Ms. Maxwell"). (Id. 1 3.) Under the order, materials properly marked CONFIDENTIAL "shall not be disclosed or used for any purpose except the prep

s" of and Maxwell Defendant Ghislaine Maxwell ("Ms. Maxwell"). (Id. 1 3.) Under the order, materials properl

ourt rules that certain discovery materials from the Maxwell case are not properly in possession of Plaintiff

gnated them CONFIDENTIAL or, alternatively, destroyed. (Id. 1 12.) 3 EFTA00074892 casgan et43g4.9kftneDiAgrAeAFIV/P4tEheif6 V- ga ef41th 13 2. Cooper & Kirk's Possession of the Maxwell Materials Before Dershowitz's 23 oral argument getting to the heart of the request, the Court was troubled to that re

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,

former counsel, Boies Schiller Flexner, various discovery materials that were subject to the Protective Order. EXHIBYI' 2 at 4. The Court rejected Cooper & Kirk's suggestion that it properly was a recipient of the material: [W]hatever Cooper & Kirk's intentions in requesting and obtaining the Maxwell material

nver, Colorado 80203 PH 303.831.7364 HI 303.832.2628 www.hmtlaw.com [email protected] Re: Reconsideration of the Court's July 23 Ruling Giuffie v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its Protective Order and punish

.com Re: Reconsideration of the Court's July 23 Ruling Giuffie v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its Protective Order and punish its violation. Ms. Maxwell's two deposition transcripts were designated

eration of the Court's July 23 Ruling Giuffie v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Presk

v. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its

ining the Maxwell materials from Boies Schiller, the Maxwell Protective Order explicitly provides that (1) di

's former counsel, Boies Schiller Flexner, various discovery materials that were subject to the Protective Order. Doc.1071 at 4. The Court rejected Cooper & Kirk's suggestion that it properly was a recipient of the material: [W]hatever Cooper & Kirk's intentions in requesting and obtaining the Maxwell material

MAXWELL JEFFREY EPSTEIN, PRINCE ANDREW, 3/22/20 EFTA00075107 Casgastetal14331atitilmetbdOnttit7187.82412CF 057g9/28gEFEeigef 6208161 Socialite Ghislaine Maxwell 'groped a 16-year-old girl during a naked massage,' victims' lawyer says El dailvmail.co.ukThews/article-8163681/Socialite-Ghislaine-Maxwell-qroped-1

.com Re: Reconsideration of the Court's July 23 Ruling Giuffie v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its Protective Order and punish its violation. Ms. Maxwell's two deposition transcripts were designated

rated for Jeffrey Epstein's personal sexual satisfaction. So to the degree that um there was a main facilitator that started the whole thing, it was Ghislaine. 3 A purported transcript of the press conference is contained on the intemet at https://www.rev.comiblog,/transcripts/announcement-transcript-of-c

v. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its

ining the Maxwell materials from Boies Schiller, the Maxwell Protective Order explicitly provides that (1) di

's former counsel, Boies Schiller Fierier, various discovery materials that were subject to the Protective Order. Doc.1071 at 4. The Court rejected Cooper & Kirk's suggestion that it properly was a recipient of the material: [W]hatever Cooper & Kirk's intentions in requesting and obtaining the Maxwell material