Epstein Secrets

LLP 401 E. David Boies Boles, Schiller & Flexner LLP Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah ' This daytime business address is provided for identification and correspondence pu

r many months now. We need them as counsel of record in the case now because we are going to have depositions country where, for example, Professor Cassell is SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00076414 Case 20-2413, Document 44. 08120/2020, 2913556, Page33 of 78 App.-0807 3 G4L

to have depositions country where, for example, Professor Cassell is SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-

Cr. 330 (AJN) (the "Criminal Action"). The information implicates Ms. Maxwell's right to due process and fairness in this civil action and affects the Second Circuit's review of the Court's unsealing order of July 23, 2020. Additionally, the information implicates her rights as a criminal defendant guaranteed unde

Produce Sealed Materials, and to Hold the Orders in Abeyance Pending Disposition of This Motion on the following persons: The Hon. Robert W. Sweet Paul G. Cassell District Judge ([email protected]) United States District Court for the Sigrid S. McCawley Southern District of New York (smccawley@bsfllp.

PPOSING PARTY: Plaintiff OPPOSING ATTORNEY: Paul Cassell address. phone number and e-mail) S.J. Quinney

at the district court (or the appellees) unjustifiably delayed resolution of the unseal motions and its abuse of discretion in failing to adhere to the Second Circuit's "clear[]"3 precedent. We respectfully submit that neither conclusion warrants the extraordinary action being contemplated by the panel. A. The dist

win Paul M. Krieger ICRIEGER KIM & LEWIN, LLP 500 Fifth Avenue New York. NY 10110 this Ms. Maxwell's Reply In Support of Her on the following: Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 Imran H. Ansari AIDALA, BERTUNA & KAMINS, P.C. 546 Fifth Avenue 6th Floor New York, NY 10036

ply In Support of Her on the following: Paul G. Cassell 383 S. University Street Salt Lake City, UT 841

re "unjustified obstacles" or that the public will never have access to these documents -- reflect unjustified criticisms of the Protocol itself and the Second Circuit's decision in Brown, both of which fairly outline the legal process for parties and Non-Parties alike to be heard with respect to unsealing. Notably,

CVRA case in which she discussed her sex trafficking by Epstein. On December 31, 2014, Plaintiff's lawyers in the CVRA proceeding (Brad Edwards and Paul Cassell) filed a Motion Pursuant to Rule 21 for Joinder in the Action ("Joinder Motion") on behalf of Plaintiff. Plaintiff's joinder motion described how s

lawyers in the CVRA actions, Brad Edwards and Paul Cassell. Defendant, in nationally televised news interviews, wrongfully claimed that Edwards and Cassell had engaged in unethical behavior warranting disbarment for filing the Joinder Motion that described Defendant's involvement with Epstein and Plaint

e is totally fantasizing about me. She's made up the whole story. There is no truth to it." (t) August 12, 2019, in a press statement issued after the Second Circuit's ruling in Giuffre v. Maxwell: "She invented the false accusation against me only in 2014, when her lawyers `pressured' her to do so for financial r

iscovery and admissibility as is set forth in the incorporated memorandum. Mr ;LETS DISCUSS - DOES THIS BROADEN THE INTERVENTION - WHAT EXACTLY HAS CASSELL ASKED FOR] Epstein also objects to any further , as-well-as-dieir-Footien-te disseminate the plea negotiation &communications or its content -to th

rrive at a just solution of a civil dispute." Lake Utopia Paper Ltd. v. Connelly Containers, Inc., 608 F.2d 928 (2d Cir.I979). Lake Utopia involved the Second Circuit's Civil Appeals Management Plan, which called for parties to engage in a conference before oral argument, to hopefully settle their dispute. The Circ