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l. Corp., 594 F.2d 291 (2d Cir. 1979) 59, 63, 77, 102 Martindell, 594 F.3d 79 Martinez v. McAleenan, 385 F. Supp. 3d 349 (S.D.N.Y. 2019) 104 Michigan v. Tucker, 417 U.S. 433 (1974) 96 Miller v. Pate, 386 U.S. 1 (1967) 108, 117, 118 Mills v. Scully, 826 F.2d 1192 (2d Cir. 1987) 108 Minnesot
ng of Maxwell's Depositions Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April 2016 deposition transcript. (See 15 Civ. 7433 (LAP), Dkt.
met that standard." (Id. at 7) (emphasis in original). 8. Unsealing of Maxwell's Depositions Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April
— who called himself her "Godfather" — when she was 13 years old. Jane Doe met Epstein and his friend, Ghislaine Maxwell, in the summer of 1994 at Michigan's interlochen Arts Camp, where she was In voice training, according to newly flied court papers suing Epstein's estate and Maxwell. The duo quickly
www.hmllaw.com [email protected] 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 depositio
Ces2e.29-12,407413r3cliAlienDtidutinEl t310282 if663615/233/2174ig Plage aoat 9 HADDON MORGAN FOREMAN 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 C Ty Gee 150 East
ly desirable." Id. at 187. "[T]he Fifth Amendment proscribes only self-incrimination obtained by a `genuine compulsion of testimony.'" Id. (quoting Michigan v. Tucker, 417 U.S. 433, 440 (1974)); see also Washington, 431 U.S. at 187 ("Absent some officially coerced self-accusation, the Fifth Amendment pri
8. Unsealing of Maxwell's Depositions Three months after Chief Judge McMahon issued her Order, Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April
ge McMahon issued her Order, Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April 74 EFTA00077706 2016 deposition transcript. (See 15 Civ
ly desirable." Id. at 187. "[T]he Fifth Amendment proscribes only self-incrimination obtained by a `genuine compulsion of testimony.'" Id. (quoting Michigan v. Tucker, 417 U.S. 433, 440 (1974)); see also Washington, 431 U.S. at 187 ("Absent some officially coerced self-accusation, the Fifth Amendment pri
8. Unsealing of Maxwell's Depositions Three months after Chief Judge McMahon issued her Order, Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April
ge McMahon issued her Order, Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April 74 EFTA00039521 2016 deposition transcript. (See 15 Civ
y desirable." Id. at 187. "[T]tle Fifth Amendment proscribes only self-incrimination obtained by a `genuine compulsion of testimony.'" Id. (quoting Michigan v. Tucker, 417 U.S. 433, 440 (1974)); see also Washington, 431 U.S. at 187 ("Absent some officially coerced self-accusation, the Fifth Amendment pri
inal). 8. Unsealing of Maxwell's Depositions Three months after Chief Judge McMahon issued her Order, v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April
ief Judge McMahon issued her Order, v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April 74 EFTA00103099 2016 deposition transcript. (See 15 Civ
r said Wednesday." US Attorney Matthew Schneider "dismissed as 'irresponsible rhetoric' any suggestion that the government wants to quash dissent in Michigan, seeking to allay fears that they would have a role similar to the one agents have had at protests in Portland, Oregon, in recent weeks. Instead, h
2015 civil lawsuit that included a deposition given by Maxwell in the case brought by Epstein accuser Virginia Giuffre. Less than three hours later, Preska denied it, citing `eleventh-hour request for reconsideration.' She allowed Maxwell's attorneys two days to seek a stay from an appeals court on two
said Wednesday." US Attorney Matthew Schneider "dismissed as 'irresponsible rhetoric' any suggestion that the government wants to quash dissent in Michigan, seeking to allay fears that they would have a role similar to the one agents have had at protests in Portland, Oregon, in recent weeks. Instead, h
015 civil lawsuit that included a deposition given by Maxwell in the case brought by Epstein accuser Virginia Giuffre. Less than three hours later, Preska denied it, citing `eleventh-hour request for reconsideration.' She allowed Maxwell's attorneys two days to seek a stay from an appeals court on two
r said Wednesday." US Attorney Matthew Schneider "dismissed as 'irresponsible rhetoric' any suggestion that the government wants to quash dissent in Michigan, seeking to allay fears that they would have a role similar to the one agents have had at protests in Portland, Oregon, in recent weeks. Instead, h
f documents in a 2015 civil lawsuit that included a deposition given by Maxwell in the case brought by Epstein accuser Less than three hours later, Preska denied it, citing 'eleventh-hour request for reconsideration.' She allowed Maxwell's attorneys two days to seek a stay from an appeals court on two
ly desirable." Id. at 187. "[T]he Fifth Amendment proscribes only self-incrimination obtained by a `genuine compulsion of testimony.'" Id. (quoting Michigan v. Tucker, 417 U.S. 433, 440 (1974)); see also Washington, 431 U.S. at 187 ("Absent some officially coerced self-accusation, the Fifth Amendment pri
materials. Giuf•e v. Maxwell, No. 20-2413 (2d Cir.) (Dkt. No. 140-1 at 2). On October 19, 2020, the Second Circuit found that Judge Preska "correctly held that the deposition materials are judicial documents to which the presumption of public access attaches, and did not abuse its discr
said Wednesday." US Attorney Matthew Schneider "dismissed as `irresponsible rhetoric' any suggestion that the government wants to quash dissent in Michigan, seeking to allay fears that they would have a role similar to the one agents have had at protests in Portland, Oregon, in recent weeks. Instead, h
015 civil lawsuit that included a deposition given by Maxwell in the case brought by Epstein accuser Virginia Giuffre. Less than three hours later, Preska denied it, citing `eleventh-hour request for reconsideration.' She allowed Maxwell's attorneys two days to seek a stay from an appeals court on two
Entities connected to both Michigan and Loretta A. Preska

Jeffrey Epstein
PERSON
Donald Trump
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Virginia Giuffre
PERSON
Julie K. Brown
PERSON
Department of Justice
ORGANIZATIONLeon Black
PERSON
George W. Bush
PERSON
United States
LOCATION
Bloomberg L.P.
ORGANIZATION
Colorado
LOCATION
Joe Biden
PERSON
Stephen Hawking
PERSON
Michael Jackson
PERSON
Prince Charles
PERSON
Bill Clinton
PERSON
Barack Obama
PERSON
George Mitchell
PERSON
Minnesota
LOCATION