Epstein Secrets

SSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: Attorneys

k indictment because they arose out of "the same conspiratorial agreement that underlay the charges dismissed in the Eastern District." Id. at 672. The Second Circuit rejected this argument finding that, as a general rule, a plea agreement only binds the prosecutor's office that entered into the agreement, unless

SSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 225 Broadway, Suite 715 New York, NY 10007 Phone: Attorneys for Ghislain

074492 prejudicial to Ms. Maxwell and will mislead the jury into believing that the alleged sex acts between Epstein and Accuser-3 were unlawful.; The Second Circuit takes an "inclusionary approach" to Rule 404(b) evidence, which admits "other act" evidence "that does not serve the sole purpose of showing the def

-DCF Document 79 Filed 09/04/20 Page 1 of 3 H A D D O N MORGAN FOREMAN Haddon, Morgan and Foreman. P.0 Laura A. Menninger ISO East 10th Avenue Denver. Colorado 80203 rti 303.831.7364 rx 303.832.2628 www.hmflaw.com Imenningerehmflaw.com September 4, 2020 VIA ECF Hon. Debra Freeman United Stat

aintiff's assertion, Ms. Maxwell has not suggested there is an "absolute right to stay this case simply because she has been indicted." Resp. at 6. The Second Circuit has a litany of factors, articulated in Louis Vuitton Malletier S.A. v. LY USA, Inc., 676 F.3d 83, 96 (2d Cir. 2012), and applied numerous times sin

ve Order (UNDER SEAL)' United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Haddon, Morgan and Foreman, t.c Jeffrey Paglloca 150 East 10th Avenue Denver, Colorado 80203 rti 303.831.7364 FX 303.832.2628 www.hmflaw.com jpaglucaahmflaw.com Dear Judge Nathan, Defendant Ghislaine Maxwell, pursuant to

t, ex pane transcripts, and ex pane rulings. Boies, Schiller & Flexner ("BSF') lawyers, cooperating with the government, are aware of the Material. The Second Circuit has characterized these types of documents as "judicial documents" with a presumptive right of public access. See Brown v. Maxwell, 929 F.3d 41, 47

lt Lake City, UT 84112, By: Paul G. Cassell, Esq. Counsel for Defendant Ghislaine Maxwell: HADDON, MORGAN AND FOREMAN, P.C., 150 East 10th Avenue, Denver, CO 80203, By: Laura A. Menninger, Esq., Jeffrey S. Pagliuca, Esq., Ty Gee, Esq. Counsel for Intervenor Michael Cemovich: RANDAZZA LEGAL GROUP, PLL

As noted above, the Protective Order specified that confidential material would not be protected with respect to any document proffered at trial. The Second Circuit has recognized two approaches for determining whether the First Amendment right of access extends to particular judicial records. Lugosch, 435 F.3d

ptocurrency scam, delaying the trial for about a month. Read full article » SECURITIES $3B Petrobras Settlement Clears Final Hurdle In 2nd Circ. The Second Circuit on Friday affirmed the approval of Petrobras' $3 billion securities class action settlement related to the Brazilian oil giants massive le"law360 P

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