Epstein Secrets

er, these are the types of pleadings that the Second Circuit has characterized as judicial documents with a presumptive right of public access. See Brown v. Maxwell, 929 F.3d 41, 47 (2d Cir. 2019). Ms. Maxwell, under paragraph 9 of the Protective Order in this case, notifies EFTA00018583 --- PAGE B

H A D D O N MORGAN FOREMAN Haddon, Morgan and Foreman, P c Jeffrey S. Paglluca P11 IIIIIIIMPPOIMIIIMPIIIMPIO www.hmflaw.com August 9, 2020 VIA EMAIL Assistant United States Attorney New York, New

ork 40 Foley Square New York, NY 10007 Re: Request to Modify Protective Order (UNDER SEAL)' United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Haddon, Morgan and Foreman, t.c Jeffrey Paglloca 150 East 10th Avenue Denver, Colorado 80203 rti 303.831.7364 FX 303.832.2628 www.hmflaw.com jpaglucaahmflaw.com Dear Jud

the Material. The Second Circuit has characterized these types of documents as "judicial documents" with a presumptive right of public access. See Brown v. Maxwell, 929 F.3d 41, 47 (2d Cir. 2019). Ms. Maxwell objected to the government's Confidential designation, under paragraph 9 of the Protective O

REMAN July 29, 2020 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, P.0 Ty Gee 150 East 10th Avenue Denver, Colorado 80203 ni 303.831.7364 rx 303.832.2628 www.hmtlaw.com tgeefghmflaw.com Re: Reconsideration of

closure of these materials to permit Defendant to make application to the U.S. Court of Appeals for the Second Circuit for a more extended stay."); Brown v. Maxwell, 929 F.3d 41, 54 (2d. Cir. 2019) (recognizing likelihood of future appeals in this matter). 1. There are new, intervening and significan