Epstein Secrets

Cagean.g0c44/ 71SEAFierbd664164i igl5V2PilaW6M/Joagria44 1?)f 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Objections to Unsealing Docket Entries 143. 173. and 199 and to Unsealing Docket Entries 164

ia44 1?)f 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Objections to Unsealing Docket Entries 143. 173. and 199 and to Unsealing Docket Entries 164 and 230 at This Time. Laura A. Menninger Jeffrey S.

RGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 EFTA00075004 CageaUlg0caAIDer0dthhilfii igl5V2Pil&iA6/2bagctacir4 2%f 3 Defendant Ghislaine Maxwell, through her counsel and pursuant to this Court's Order and Protocol for Unsealing Decided Motions, DE 1044, as clarified by DE 1053, objects to the

supporting continued sealing/redaction of the item, and (c) whether the countervailing interests rebut the presumption of public access to the item. n. Maxwell, No. 15-CV-07433-LAP, 2020 WL 1547377, at *1 (S.D.N.Y. Mar. 31, 2020); DE 1044.' Based on the Court's clarification of its March 31, 2020 Order, DE

ISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Objections to Unsealing Docket Entries 143. 173

ieRFIWO4leiffigigkeaPab%c1e-af 17 VIII. DE 164 (and related DEs 165, 165-8, 185-3, 185-11, 185-14, 185-15). Should Remain Sealed Pending Additional Non-Party Notice and Responses Pursuant to The Protocol. The pleadings related to DE 164 concern discovery related to a waiver of Plaintiff's attorney client privi

w York, NY 10007 By Email ONLY Dear Judge Nathan, Date 21.t April 2021 Our Ref Your Ref: STRICTLY PRIVATE AND CONFIDENTIAL We represent a n Ghislaine Maxwell. We are writing to you ahead of Maxwell's upcoming criminal trial to request that all variations of our client's name be redacted from court papers

Date 21.t April 2021 Our Ref Your Ref: STRICTLY PRIVATE AND CONFIDENTIAL We represent a n Ghislaine Maxwell. We are writing to you ahead of Maxwell's upcoming criminal trial to request that all variations of our client's name be redacted from court papers. We have copied both the Prosecutor and

CTLY PRIVATE AND CONFIDENTIAL We represent a n Ghislaine Maxwell. We are writing to you ahead of Maxwell'

requiring any requests for redaction of documents by today — April 210 2021. This letter/email is such a request. In the Previcins (nee EM) and Ghislaine Maxwell, our client was not initially made aware by the court or any of the representatives of the parties of the availability to make an application for he

ght to seek redaction she instructed this firm to represent her and we made such application to Judge Loretta Preska which was granted. We signed a Non-Party Notice and Order and were able to obtain the relevant documents to have our client's name redacted. use the term 'panner todescribe a Senior Solicitor, Em

mail ONLY Date 21.t April 2021 Our Ref MJM/TAYO/1 Your Ref: Dear Judge Nathan, STRICTLY PRIVATE AND CONFIDENTIAL We represent a former PA to Ghislaine Maxwell. We are writing to you ahead of Maxwell's upcoming criminal trial to request that all variations of our client's name be redacted from court papers

/1 Your Ref: Dear Judge Nathan, STRICTLY PRIVATE AND CONFIDENTIAL We represent a former PA to Ghislaine Maxwell. We are writing to you ahead of Maxwell's upcoming criminal trial to request that all variations of our client's name be redacted from court papers. We have copied both the Prosecutor and

ests for redaction of documents by today — April 210 2021. This letter/email is such a request. In the previous defamation proceedings between and Ghislaine Maxwell, our client was not initially made aware by the court or any of the representatives of the parties of the availability to make an applicati

ght to seek redaction she instructed this firm to represent her and we made such application to Judge Loretta Preska which was granted. We signed a Non-Party Notice and Order and were able to obtain the relevant documents to have our client's name redacted. Manlays use the term 'panne? to describe a Senior Soli