Epstein Secrets

and, of eiti-zea-ef-the-14nite€1-States (within the Southern District of New York). 8. At all times material to this cause of action was residinga United States citizen, employed by New York based company and regularly conducting business in New York, New York and, on information and belief, was a citizen o

ll called Plaintiff-'s parents in South Africa to tell them that DefendentsDefendant Epstein would take good care of Plaintiff when she returned to the United State; and that theyDefendants Maxwell and Epstein would use their connections and influence EFTA00296300 Case 1:17-cv-00616-JGK Document 45 Filed 06/0

30 of 31 29 EFTA00296308 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 30 of 31 By: /s/ Bradley J. Edwards Bradley J. Edwards BOLES, SCHILLER & FLEXNER LLPPry4 David Boies_ David Boies- Boies Schiller & Flexner LLP Sigrid McCawley Meredith Schultz Boies Schiller & Flexner LLP Paul C Cassell •

counsel stated in a phone conversation that Mr. Brunel's counsel said his client had gone to France and it was unclear when he would be returning to the United States. Following the filing of the instant motion, counsel for Ms. Maxwell requested copies of the certificates of service for all of Plaintiff's Rule 45

ANCTIONS FOR VIOLATION OF RULE 45 via ECF on the following: Sigrid S. McCawley Paul G. Cassell Meridith Schultz 383 S. University Street BOIES, SCHILLER & FLEXNER, LLP Salt Lake City, UT 84112 401 East Las Olas Boulevard, Ste. 1200 [email protected] Ft. Lauderdale, FL 33301 [email protected] mschul

in and Maxwell called Plaintiff's parents in to tell them that DefenElantsDefendant Epstein would take good care of Plaintiff when she returned to the United State; and that theyDefendants Maxwell and Epstein would use their connections and influence EFTA00615993 Case 1:17-cv-00616-JGK Document 45 Filed 06/0

ge 30 of 31 29 EFTA00616001 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 30 of 31 By: A/Bradley J. Edwards Bradley J. Edwards BOIES, SCHILLER & FLEXNER LLPB.5 David Boies_ David Boies- Alex Boies Boics Schiller & Flcxncr LLP 575 Sigrid McCawley Meredith Schultz HAC VICE-te-befiled Paul G Casse

n abuse of discretion occurs if the district court fails to make the required factual findings, or if those factual findings are clearly erroneous." United States v. Juvenile Male No. 1, 47 F.3d 68,71 (2d Cir. 1995) (citation omitted). B. The district court erred in ordering the unsealing. There are "two rela

nt. x 9 New York, N.Y. 10 July 23, 2020 11:30 a.m. 11 Before: 12 HON. LORETTA A. PRESKA, 13 District Judge 14 APPEARANCES 15 BOIES, SCHILLER & FLEXNER, LLP 16 Attorney for Plaintiff BY: SIGRID S. MCCAWLEY 17 HADDON, MORGAN, AND FOREMAN, P.C. 18 Attorney for Defendant BY: LAURA A. MENNINGER