Epstein Secrets

potential co- conspirators of Epstein" evolved from a more narrow provision sought by the defense. The provision expanded as [USAO-SDFL prosecutor Maria] Villafana and defense counsel exchanged drafts of, first, a proposed federal plea agreement and, then, of the NPA, with apparently little analysis

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

District of New York declined to comment on the investigation. Maxwell's attorney cited the investigation in an effort to block her testimony in the Farmer case. .1.11ALL2 Ghislaine Maxwell wins questioning delay in sexual battery suit "The Southern District of New York has publicly and repeatedly a

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

mental ambiguity," however, "is the exception, not the rule." United States v. Sarwari, 669 F.3d 401, 407 (4th Cir. 2012) (quoting United States v. Farmer, 137 F.3d 1265, 1269 (10th Cir. 1998)). A defendant cannot demonstrate fundamental ambiguity simply by showing that words used in a question are ame

irc ompe "unalMer eluded e Govan nut that ed to hasis in 8. Unsealing of Maxwell's Depositions v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judgg Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April

ing, and related to, Maxwell's April 74 EFTA00100041 2016 deposition transcript. (See 15 Civ. 7433 (LAP), Dkt. No. 1077). Maxwell appealed Judge Preska's order, arguing that the court abused its discretion in ordering the unsealing of the deposition materials and that Maxwell's interests outweighed

d following the development of a full factual record. See, e.g., Strohm, 671 at 1175 (appeal following conviction); SanvaH, 669 F.3d at 406 (same); Farmer, 137 F.3d at 1269 (appeal following conviction and partial Rule 29 dismissal) Marldewicz, 978 F.2d at 808 (appeal following conviction); cf. United

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

d following the development of a full factual record. See, e.g., Strohm, 671 at 1175 (appeal following conviction); SanvaH, 669 F.3d at 406 (same); Farmer, 137 F.3d at 1269 (appeal following conviction and partial Rule 29 dismissal) Marldewicz, 978 F.2d at 808 (appeal following conviction); cf. United

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

following the development of a full factual record. See, e.g., Strohm, 671 at 1175 (appeal following conviction); Sarivari, 669 F.3d at 406 (same); Farmer, 137 F.3d at 1269 (appeal following conviction and partial Rule 29 dismissal) Marldewicz, 978 F.2d at 808 (appeal following conviction); cf. United

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

nd that personal service would be impracticable. See Ransome v. Epstein, No. 17cv616 (JGK), 2018 WL 637421, at *1 (S.D.NY. Jan. 30, 2018); see also Farmer v. lndyke, No. 19cv10475 (LGS)(DF) (Text Order, dated Feb. 12, 2020). This Court further finds that Plaintiff's provision of a copy of the Summons

ia.cominews/politics/2020/01/23/ghisla i ne-maxwell s-lawyers-adm it-they-dont-know- where-she-is-either/), which refers to a letter filed with Judge Preska in January 2020, and dated December 2019. The article claims that the letter admitted Maxwell's lawyers don't know where their client is. Maxwell's

& Flexner LLP Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L

Haddon. Morgan and Foreman. PC Laura A. Menninger www hmacrw tom 2020 Order (Doc. 1096) v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: I write in response to the Court's Order of August 3, 2020 (Doc. 1069), the Order and Protocol for Unsealing Decided Motions (Doc. 1044) ("Protoco