Epstein Secrets

h Peter Skinner, Stan Pottinger, and Brad Edwards EXHIBIT L: Email String Between Peter Skinner and AUSA cc'ing Stan Pottinger, Brad Edwards, and Sigrid McCawley (Feb. 29, 2016—Mar. 5, 2016) (Sealed) EXHIBIT M: Emails between AUSA and Chief of the Criminal Division (Mar. 3, 2016) (Sealed) EXHIBIT N: Emails

cc'ing Stan Pottinger, Brad Edwards, and Sigrid McCawley (Feb. 29, 2016—Mar. 5, 2016) (Sealed) EXHIBIT M:

between AUSA and AUSA and other AUSAs (Nov. 30, 2018—Dec. 6, 2018) (Sealed) EXHIBIT O: Email from Stan Pottinger to AUSA cc'ing Brad Edwards and Sigrid McCawley, re Daniel Siad (Mar. 3, 2016) (Sealed) EXHIBIT P: Supplemental Privilege Log, Apr. 4, 2016 EXHIBIT Q: Defendant's Response in Opposition to Motio

imum, this Court Should Order a Hearing at which Maxwell May Inquire into the Circumstances Surrounding the Government's Misrepresentation to Judge McMahon 26 Conclusion 27 Certificate of Service 29 EFTA00077572 Table of Authorities Cases Abdell v. City of New York, No. 05 CIV. 8453 KMK JCF, 20

various Does, the lawyers for primarily Sigrid McCawley, a partner at BSF, and counsel for Ms. Maxwell. J

ining or unsealing the sealed status of thousands of pages of material. Judge Preska sought input from the various Does, the lawyers for primarily Sigrid McCawley, a partner at BSF, and counsel for Ms. Maxwell. Judge Preska was obligated by the Brown Court first to identify what was or was not a "judicial docu

s deposition on July 23 and denied Ms. Maxwell's motion to reconsider on July 30, she apparently did not know that, as described below, Chief Judge McMahon had already granted an ex pane request from the government to obtain Ms. Maxwell's deposition (among thousands of other confidential and sealed mate

never received that email from Martin Weinberg. All of the preceding communications, however, indicate that Mr. Weinberg promptly responded to Ms. McCawley's inquiries. See, e.g., Poe Declaration, Ex. 2 (email of April 6 from Weinberg to McCawley (offering to let her know regarding acceptance of service

DUM OF LAW IN OPPOSITION TO EXTENDING DEADLINE TO COMPLETE DEPOSITIONS AND MOTION FOR SANCTIONS FOR VIOLATION OF RULE 45 via ECF on the following: Sigrid S. McCawley Paul G. Cassell Meridith Schultz 383 S. University Street BOIES, SCHILLER & FLEXNER, LLP Salt Lake City, UT 84112 401 East Las Olas Boulevard,

524611 at *7 (S.D.N.Y. Aug. 14, 2009) (emphasis added) (citing Rent-A-Center Inc. v. 47 Mamaroneck Ave. Corp., 215 F.R.D. 100, 104 (S.D.N.Y. 2003) (McMahon, J.)); accord Parker v. Columbia Pictures Indus., 204 F.3d 326, 340 (2d Cir. 2000) (" IGJood cause' depends on the diligence of the moving party.")

important, accuracy was just as high in the CI interviews as in the comparison interviews (for reviews, see Bekerian and Dennett, 1993; Fisher and McCauley, 1995 and Fisher & Schreiber, 2007). The CI also typically does not contribute to the creation of false memories (Sharman & Powell, 2013), but inste

on, Granhag, & Spjut, 2003; McCauley & Fisher, 1995; Saywitz et al., 1992), in some studies, the witnesses were older people (Mello & Fisher, 1996; McMahon, 2000), and in some studies, the witnesses were young adults with learning disabilities or some other cognitive deficit (Brown & EFTA01657026 14

imum, this Court Should Order a Hearing at which Maxwell May Inquire into the Circumstances Surrounding the Government's Misrepresentation to Judge McMahon 26 Conclusion 27 Certificate of Service 29 EFTA00029101 --- PAGE BREAK --- Table of Authorities Cases Abdell v. City of New York, No. 05 C

h Peter Skinner, Stan Pottinger, and Brad Edwards EXHIBIT L: Email String Between Peter Skinner and AUSA cc'ing Stan Pottinger, Brad Edwards, and Sigrid McCawley (Feb. 29, 2016—Mar. 5, 2016) (Sealed) EXHIBIT M: Emails between AUSA and Chief of the Criminal Division (Mar. 3, 2016) (Sealed) EXHIBIT I: Emails

led) EXHIBIT I: Emails between AUSA and AUSA and other AUSAs (Nov. 30, 2018—Dec. 6, 2018) (Sealed) EXHIBIT O: Email from Stan Pottinger to AUSA McCawley, re Daniel Siad (Mar. 3, 2016) (Sealed) cc'ing Brad Edwards and Sigrid EXHIBIT P: Supplemental Privilege Log, Apr. 4, 2016 EXHIBIT Q: Defendant's

2018—Dec. 6, 2018) (Sealed) EXHIBIT O: Email from Stan Pottinger to AUSA McCawley, re Daniel Siad (Mar. 3, 2016) (Sealed) cc'ing Brad Edwards and Sigrid EXHIBIT P: Supplemental Privilege Log, Apr. 4, 2016 EXHIBIT Q: Defendant's Response in Opposition to Motion to Exceed Presumptive Ten Deposition

imum, this Court Should Order a Hearing at which Maxwell May Inquire into the Circumstances Surrounding the Government's Misrepresentation to Judge McMahon 26 Conclusion 27 Certificate of Service 29 EFTA00028930 --- PAGE BREAK --- Table of Authorities Cases Abdell v. City of New York, No. 05 C

h Peter Skinner, Stan Pottinger, and Brad Edwards EXHIBIT L: Email String Between Peter Skinner and AUSA cc'ing Stan Pottinger, Brad Edwards, and Sigrid McCawley (Feb. 29, 2016—Mar. 5, 2016) (Sealed) EXHIBIT M: Emails between AUSA and Chief of the Criminal Division (Mar. 3, 2016) (Sealed) EXHIBIT N: Emails

led) EXHIBIT N: Emails between AUSA and AUSA and other AUSAs (Nov. 30, 2018—Dec. 6, 2018) (Sealed) EXHIBIT O: Email from Stan Pottinger to AUSA McCawley, re Daniel Siad (Mar. 3, 2016) (Sealed) cc'ing Brad Edwards and Sigrid EXHIBIT P: Supplemental Privilege Log, Apr. 4, 2016 EXHIBIT Q: Defendant's