Epstein Secrets

0007 Re: Au 3, 2020 Order (Doc. 1096) v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Haddon, Morgan and Foreman, P C Laura A. Menninger Denver, Colorado 80203 wvow.hmilaw.com Dear Judge Preska: I write in response to the Court's Order of August 3, 2020 (Doc. 1069), the Order and Protocol for Unsea

18 (Exhibit A). As required by that Protective Order and Judge Nathan's Individual Practices in Criminal Cases, counsel initiated a conferral with the U.S. Attorney's Office over the weekend concerning a modification of the Protective Order to share the information with this Court and the Second Circuit. Barring agreeme

es v. United States, a federal case in the U.S. District Court for the Southern District of Florida, usefully illustrates the issue. *° In that case, the U.S. Attorney's Office for the Southern District of Florida 22 Td. 33 Td. at 7302 (statement of Sen. Jon Kyl). 34 Compare /8 U.S.C. § 3771(d), with Susan Bandes, Victim S

d a possible consultation right long before formal charges are filed. [*100] Other states also expressly extend rights before the filing of charges. Colorado guarantees rights at "all critical stages of the criminal justice process[,]" which includes both the filing of charges and the decision to not file

-- TABLE OF AUTHORITIES Cases Boyd v United States, 116 U.S. 616 (1886) 3, 6, 15 Carpenter v. United States, 138 S. Ct. 2206 (2018) 3, 5, 6, 9 Colorado v. Bannister, 449 U.S. 1 (1980) 3 DeMassa v. Nunez, 770 F.2d 1505 (9th Cir. 1985) 10 Doe v. Broderick, 225 F.3d 440 (4th Cir. 2000) 10, 13 Fi

and the Fi h Amendment to Suppress All Evidence Obtained from the government's Subpoena t and to Dismiss Counts Five and Six upon the following: U.S. Attorney's Office SDNY New York, NY 10007 s/ Christian R. Everdell 18 EFTA00015324

a citizen of the State of Colorado. 7. Defendant Maxwell, who is domiciled in the Southern District of New York, is not a citizen of the state of Colorado. FACTUAL ALLEGATIONS 8. became a victim of sex trafficking and repeated sexual abuse after being recruited by Ghislaine Maxwell and Jeffrey Epste

00015728 --- PAGE BREAK --- Case 1:15-cv-07433-LAP Document 1 Filed 09/21/15 Page 4 of 12 15. Rather than confer with the victims about the NPA, the U.S. Attorney's Office and Epstein agreed to a "confidentiality" provision in the Agreement barring its disclosure to anyone—including Epstein's victims. As a consequence