Epstein Secrets

2020 Ruling, Dated July 29, 2020 (Dkt. 1079) App.-0777 Notice of Appeal, Dated July 29, 2020 (Dkt. 1081) App.-0781 Non-Redacted Declaration of Sigrid S. McCawley In Support of Plaintiff's Motion to Exceed Presumptive Ten Deposition Limit in Federal Rule of Civil Procedure 30(A)(2)(a)(ii), Dated July 30, 202

112210rrbotóriS11/059320 Itibeibig0tat 1 PaOS of 4 App.-0785 Dated: May 27, 2016. Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawlev Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boles_ Schiller & Flexner LLP 401 E. David Boies Boles, Schiller & Flexner LLP B

A: Absolutely. 10 THE COURT: You can go over to the corner, too. 11 MR. PAGLIUCA: I think we need a corner bar on this, 12 your Honor. 13 Ms. McCawley, I'm wondering if we can get a mutually 14 convenient date to hear that matter as opposed to next 15 Thursday. 16 MS. McCAWLEY: Of course. 17

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

N.Y. January 19, 2021 10:10 a.m. HON. LORETTA A. PRESKA, District Judge APPEARANCES BOIES SCHILLER & FLEXNER LLP Attorneys for Plaintiff BY: SIGRID S. McCAWLEY HADDON MORGAN and FOREMAN, P.C. Attorneys for Defendant BY: LAURA A. MENNINGER HOLLAND & KNIGHT Attorneys for Intervenors Julie Brown and Miami He

the motion for sanctions. Unseal and redact only medical information and names and identifying information of nonparties. 258. Declaration of Ms. McCawley. Unseal and redact only names and identifying information of nonparties. I will SOUTHERN DISTRICT REPORTERS, P.C.•• (212) 805-0300 EFTA00082174

ng, ladies and gentlemen. Not that you are required to be present, but who is on for Ms. a please? MS. McCAWLEY: Good morning, your Honor. It is Sigrid McCawley from the law firm of Boies Schiller & Flexner on behalf of THE COURT: Good morning. Who is on for Ms. Maxwell, please? MS. MENNINGER: Good mornin

Messages involving the defendant. Portions of this document were redacted and released by the Second Circuit. So whatever happened with respect to the Second Circuit's release, we will abide by its ruling. 339. Response in opposition to the motion to compel. Unseal and redact the names, identifying information, a

ided Motions. 19 EFTA00075046 CasqaP.1§46t43g-tAltneattarheAFM6804146§k4,26aIniAeL436f 24 Dated: June 24, 2020 20 Respectfully Submitted, /s/ Sigrid S. McCawley Sigrid S. McCawley Counsel for Plaintiji EFTA00075047 caceangfeA1743g ccArelicatiileit7gSrogef0Filgied§(24PagePaO ilof 7 Exhibit A Plaintiff's

2020 20 Respectfully Submitted, /s/ Sigrid S. McCawley Sigrid S. McCawley Counsel for Plaintiji EFTA0

jections to unsealing. Maxwell's objections are inconsistent with the Court's May I, 2020 Order, the presumption of public access to documents, and the Second Circuit's instructions when it remanded this matter nearly a year ago. Further, Maxwell's objections are extraordinarily general and vague, and cannot defeat

fessional relationships as well as matters concerning her private affairs." • March 17, 2016 (DE 66 at 9): At hearing on the Protective Order, Ms. McCawley stated "I can have the deposition of the defendant in this case and move this case forward. I will agree to their protective order. I just want tha

aration of Laura A. Menninger in Support of Ms. Maxwell's Reply In Support of Her Objection to Unsealing Sealed Material via ECF on the following: Sigrid S. McCawley Meredith Schultz Bows, $CHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale. FL 33301 Bradley J. Edwards Stan J. Potti

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,

United States District Court for the Sigrid S. McCawley Southern District of New York (smccawley@bsfllp

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