Epstein Secrets

g interest in "weighing the interests advanced by the parties in light of the public interests and the duty of the courts," Nixon, 435 U.S. at 602. See United States v. Cicale, No. 05-CR-60-2 (NGG), 2018 WL 388941, at *3 (E.D.N.Y. Jan. 11, 2018) ("Compelling interests warranting closure of a courtroom—and, by ex

s, to 12 EFTA00075086 cagsVg14,4 c St Ptet4D4s4kiwATIPAteSEilg jkle::747;7;?i, 144f319 wit, transportation of minors, in violation of Title 18, United States Code, Section 2423(a). 16. It was a part and object of the conspiracy that GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and

le v. Deutsche Bank AG, 377 F.3d 133, 144 (2d Cir. 2004), before the interested parties have an opportunity to seek review of the orders. See, e.g., United Staten. Martoma, No. Si 12 CR 973 PGG, 2014 WL 164181, at •8 (S.D.N.Y. Jan. 9, 2014) ("The Court stays immediate disclosure of these materials to permit Def

oretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, P C Ty Gee 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 HI 303.832.2628 www.hmllaw.com [email protected] Re: Reconsideration of the Court's Jul

le V. Deutsche Bank AG, 377 F.3d 133, 144 (2d Cir. 2004), before the interested parties have an opportunity to seek review of the orders. See, e.g., United Staten. Martoma, No. 5112 CR 973 PGG, 2014 WL 164181, at •8 (S.D.N.Y. Jan. 9, 2014) ("The Court stays immediate disclosure of these materials to permit Defe

g interest in "weighing the interests advanced by the parties in light of the public interests and the duty of the courts," Nixon, 435 U.S. at 602. See United States v. Cicale, No. 05-CR-60-2 (NGG), 2018 WL 388941, at *3 (E.D.N.Y. Jan. 11, 2018) ("Compelling interests warranting closure of a courtroom—and, by ex

oretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, r.0 Ty Gee 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 HI 303.832.2628 www.hmtlaw.com [email protected] Re: Reconsideration of the Court's Jul

motion misstated the right-to-access law. To the contrary the Opinion correctly summarized the law, and properly identified the leading cases from the United States Supreme Court and this Court. See, e.g., Sp.App. 16-26. The gravamen of the appellants' argument centered on—and many of the panel's questions were

nsidered and vacated MOVING PARTY: Defendant Ghislaine Maxwell OPhintiff DDefendant ['Appellant/Petitioner nAppeUee/Respondent MOVING ATTORNEY: Ty Gee [name of attorney, with fm. Haddon, Morgan and Foreman, P.C. v. Maxwell OPPOSING PARTY: Plaintiff OPPOSING ATTORNEY: Paul Cassell address. phon

s filed on September 21, 2015 at which time Plaintiff was living in Colorado and Defendant Ghislaine Maxwell was living in New York. Plaintiff is a United States Citizen. Plaintiff is seeking damages in excess of $75,000.00. Defendant's Statement: Ms. Maxwell agrees with the Plaintiff's statement, above. i

St. Salt Lake City, UT 84112 (801) 585-52025 Counsel for Plaintiff By: /s/ Jeffrey S. Pagliuca Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. Ty Gee (pro hac vice pending) HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Counsel for Defendant, Ghi

s filed on September 21, 2015 at which time Plaintiff was living in Colorado and Defendant Ghislaine Maxwell was living in New York. Plaintiff is a United States Citizen. Plaintiff is seeking damages in excess of $75,000.00. Defendant's Statement: Ms. Maxwell agrees with the Plaintiff's statement, above. i

University of Utah 383 University St. 84112 Counsel for Plainttg, By: /s/ Jeffrey S. Pagliuca Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. Ty Gee (pro hac vice pending) HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: Counsel for Defendant, Ghislaine Maxwell

ng In re von Bulow, 828 F.2d 94, 99 (2d Cir. 1987))). At that point, particularly in the Internet age, the horse is irrevocably out of the barn. See United States v. Bolton, F. Supp. 3d , 2020 WL 3401940, at *4 (D.D.C. No. 1:20- CV-1580 (RCL), June 20, 2020) (declining to enjoin publication of a book by form

Motion to Stay Pending Appeal or, in the Alternative, Motion for a Temporary Administrative Stay Pending Full Consideration of the Motion to Stay Ty Gee Laura Menninger Adam Mueller Z1LLUI JW llyt/Gtialtt Llftt-1lLttliG EFTA00074904 Case 20-2413. Document 10-1, 07/30/2020, 2896538, Page3 of 38

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

venors. ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, 15-CV-7433 (LAP) Ghislaine Maxwell's Opening Brief Ty Gee Adam Mueller HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Den r 2 Tel. Attorneys for Defendant-Appellant Ghislaine Maxwell EFTA0007547