Epstein Secrets

ng Docket Entries 164 and 230 at This Time. Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 EFTA00075004 CageaUlg0caAIDer0dthhilfii igl5V2Pil&iA6/2bagctacir4 2%f 3 Defendant Ghislaine Maxwell, through her counsel and pursuant

nt is filed with a court, it is a judicial document; otherwise it is not. See id. (citing Pansy, 23 F.3d at 782). The Amodeo I court cited two other Third Circuit cases confirming that circuit's litmus-test approach to identifying judicial documents: Bank of America National Trust and Savings Association v. H

ppellee U.S. in No. 85-1009. Albert M. Pearson, University of Georgia School of Law, Athens, Ga., and Scott McLarty, Athens, Ga. (Cecil Hartman, Denver, Cob., with them on the brief), for defendant-appellant, Kowalik. Thomas M. O'Rourke, Asst. Atty., Denver, Colo. (Robert N. U.S. Atty., with hi

nding that it was not frivol- ous. It is a `close' question or one that very well could be decided the othe " Gi- ancola, 754 F.2d at 901. In the Third Circuit said that a "substan r ues- tion under § 3143(6)(2) is one white is either novel, which has not been decided by controllaedent, or which is fairl

ork, NY 10022 Phone: Jeffrey S. Pagliuca (pro hoc vice admission pending) Laura A. Menninger HADDON, MORGAN & FORMAN P.C. 150 East 10th Avenue Denver Colorado 80203 Phone: Attorneys for Ghislaine Maxwell EFTA00093090 cggeei%Jdfod-Asouxatiptddcdniiii91O3W4d#SPAPdgeWcfrigisl TABLE OF CONTENTS

d. Cir. 1982). Every circuit with published pattern instructions inform juries that they are not to consider the indictment as evidence. See, e.g., Third Circuit ("An indictment is simply a description of the charge(s) against a defendant. It is an accusation only. An indictment is not evidence of anything,