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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
hat counsel for the Party receiving Protected Material objects to the CONFIDENTIAL designation of any or all such items, said counsel shall provide the Producing Party and, if different, the Designating Party written notice of, and the basis for, such objections. The Parties will use their best efforts to resolve
TO: Laura Menninger, Esq. Haddon, Morgan and Foreman, P.C. Fax No. Telephone No. FROM: Sigrid S. McCawley, Esq. DATE: February 26, 2016 RE: r. Maxwell, Case no. 15-cv-07433-RWS Total Number of Pages: 26 (including this cover sheet) MESSAGE: Attached please find a copy of my email transmission
1:15-cv-07433-LAP Document 1078-4 Filed 07/29/20 Page 3 of 1010019/0026 United States District Court Southern District Of New York Plaintiff, v. Ghislaine Maxwell, Defendant. 15-cv-07433-RWS AGREED PROTECTIVE ORDER Upon a showing of good cause in support of the entry of a protective order to protect the di
McCawley, Esq. DATE: February 26, 2016 RE: r. Maxwell, Case no. 15-cv-07433-RWS Total Number of Pages
t Southern District Of New York Plaintiff, v. Ghislaine Maxwell, Defendant. 15-cv-07433-RWS AGREED PRO
hat counsel for the Party receiving Protected Material objects to the CONFIDENTIAL designation of any or all such items, said counsel shall provide the Producing Party and, if different, the Designating Party written notice of, and the basis for, such objections. The Parties will use their best efforts to resolve
Laura Menninger, Esq. Haddon, Morgan and Foreman, P.C. Fax No. Telephone No. FROM: Sigrid S. McCawley, Esq. DATE: February 26, 2016 RE: .r . Maxwell, Case no. 15-cv-07433-RWS Total Number of Pages: 26 (including this cover sheet) MESSAGE: Attached please find a copy of my email transmission
:15-cv-07433-LAP Document 1078-4 Filed 07/29/20 Page 3 of 1010019/0026 United States District Court Southern District Of New York Plaintiff, v. Ghislaine Maxwell, Defendant. 15-cv-07433-RWS AGREED PROTECTIVE ORDER Upon a showing of good cause in support of the entry of a protective order to protect the di
t Southern District Of New York Plaintiff, v. Ghislaine Maxwell, Defendant. 15-cv-07433-RWS AGREED PRO
hat counsel for the Party receiving Protected Material objects to the CONFIDENTIAL designation of any or all such items, said counsel shall provide the Producing Party and, if different, the Designating Party written notice of, and the basis for, such objections. The Parties will use their best efforts to resolve
Entities connected to both Ghislaine Maxwell and the Producing Party
the Southern District
LOCATIONLaura Menninger
PERSON
David Boies
PERSONSigrid McCawley
PERSONBates
PERSON
Foreman
PERSONHaddon
PERSONSCHILLER & FLEXNER LLP
ORGANIZATIONthe Protected Material
ORGANIZATIONChallenging Designations Of Protected Material
ORGANIZATIONthe Receiving Party
ORGANIZATIONCONFIDENTIALshall
ORGANIZATIONthe non-party
ORGANIZATION