Epstein Secrets

eclare as follows: 1. Iam an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. Iam a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit

py of [A 19. Attached as Exhibit R is a true and correct copy of a press release in the Edwards, et. al vy. Dershowitz matter, dated April 8, 2016, Bates stamped GM_00523-4. HOUSE_OVERSIGHT_014799 --- PAGE BREAK --- Case 1:15-cv-07433-RWS Document 751 Filed 03/17/17 Page 4 of 5 20. Attached as Exhi

ith their legibility) the following or other appropriate notice: "CONFIDENTIAL." Discovery material designated CONFIDENTIAL shall be identified by Bates number. To the extent practical, the respective legend shall be placed near the Bates number. 8. Designation of a document as CONFIDENTIAL INFORMA

he Court in this matter, it shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. 11. A party may object to the designation of particular CONFIDENTIAL INFORMATION by giving written notice to the party designating the disputed

ith their legibility) the following or other appropriate notice: "CONFIDENTIAL." Discovery material designated CONFIDENTIAL shall be identified by Bates number. To the extent practical, the respective legend shall be placed near the Bates number. 8. Designation of a document as CONFIDENTIAL INFORMA

he Court in this matter, it shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. 11. A party may object to the designation of particular CONFIDENTIAL INFORMATION by giving written notice to the party designating the disputed

f Government Information Services ("OGIS"). (Ex. B.) (8) On August 28, 2017, Plaintiffs, through counsel, filed their First Amended Complaint with the United States District Court for the Southern District of New York.2 (ECF 1 An eFOIA is an electronic means by which requesters can submit FOIA requests to the FBI, online, through the FBI's public website, www.FBI.g

processed prior to July 2019 consecutively as "03956-1 through 03956-11571." These records are referred to in this declaration collectively as the Bates-stamped or Bates-numbered records.' I On the pages released in full or in part, these " In contrast, records processed after July 2019 were not Bate