Epstein Secrets

ed" to learn that plaintiff's successor counsel, Cooper & Kirk, had received from plaintiff's former coun

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

ed" to learn that plaintiff's successor counsel, Cooper & Kirk, had received from plaintiff's former coun

Case 1:15-cv-07433-LAP Document 1078 Filed 07/29/20 Page 1 of 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, r.0 Ty Gee 150 East

www.hmtlaw.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

principle? Does your argument mean that Professor Dershowitz can go on TV seven days a week, 20 channels a day forever and say the same things? Mr. Cooper: Yes, your Honor. (Tr. 4:23-5:2, Sept. 24, 2019) a a * The Court: So that is essentially if you put it on the intemet you're immune. Mr. Cooper: Y

ing that she was forced to engage in sexual activity with him. Defendant moved to dismiss and to disqualify law firm Holdings: The District Court, Loretta A. Preska, Senior District Judge, held that: III single publication rule did not apply to bar claim on limitations grounds; (2) plaintiffs allegations were

ld. LLP Attorneys for Alan Dershowitz Howard M. Cooper Christian G. Kiely Kristine C. Oren Cooper & K

date as confidential under the applicable protective order. Our efforts to have the transcripts unsealed and made public have been denied by Judge Preska. Also denied was our request to provide the transcript to your office so that you could determine, on an informed basis, whether it would be appropr

. LLC 652 F. Supp. 2d 1252 (M.D. Fla. 2009) 12 Cooper Industries. Inc. v. Leatherman Tool Group. Inc.,

g Petroleum Products standard to confidential materials): E Gallo Winery v. Encana Energy Servs.. Inc.. 33 Media L. Rep. 1413. 1414 (S.D.N.Y. 2005) (Preska, J.) (applying petroleum Products standard to both confidential sources and confidential materials) (copy annexed as Ex. A to Carroll Reply Decl.);

. LLC 652 F. Supp. 2d 1252 (M.D. Fla. 2009) 12 Cooper Industries. Inc. v. Leatherman Tool Group. Inc.,

g Petroleum Products standard to confidential materials): E Gallo Winery v. Encana Energy Servs.. Inc.. 33 Media L. Rep. 1413. 1414 (S.D.N.Y. 2005) (Preska, J.) (applying petroleum Products standard to both confidential sources and confidential materials) (copy annexed as Ex. A to Carroll Reply Decl.);

orneys after learning that her successor counsel, Cooper & Kirk, had received from her former counsel, Bo

-mail) Haddon, Morgan and Foreman, P.C. Boies Schiller & Flexner LLP OPPOSING ATTORNEY: Sigrid McCawley Court- Judge/ Agency appealed from: Hon. Loretta A. Preska, District Judge (S.D.N.Y.) Please check appropriate boxes: Has movant notifiedr oposing counsel (required by Local Rule 27.1): lElYes I [No (expla

ld, LLP Attorneys for Alan Dershowitz Howard M. Cooper Christian G. Kiely Kristine C. Oren - 2 - AID

date as confidential under the applicable protective order. Our efforts to have the transcripts unsealed and made public have been denied by Judge Preska. Also denied was our request to provide the transcript to your office so that you could determine, on an informed basis, whether it would be appropr

Case 1 15-cv-07433-LAP Document 1078 Filed 07/29/20 Page 1 of 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.0 Ty Gee 150 East

www.hmtlaw.com tgeefghmflaw.com Re: Reconsideration of the Court's July 23 Ruling Giuffre 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

to the Protective Order. Doc.1071 at 4. The Court rejected Cooper & Kirk's suggestion that it properly was a recipient of the material: [W]hatever Cooper & Kirk's intentions in requesting and obtaining the Maxwell materials from Boies Schiller, the Maxwell Protective Order explicitly provides that (1