Epstein Secrets

Ghislaine Maxwell's Opening Brief Ty Gee Adam Mueller HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th

order unsealing the deposition material, including Ms. Maxwell's April 2016 deposition transcript. On July 23, over Ms. Maxwell's objection, Judge Preska —who is presiding over the civil case and the litigation about the unsealing of the district court filings —ordered the complete unsealing of Ms. M

CM/ECF, which will send notification of the filing to all counsel of record. I also certify that I mailed a copy of the opening brief to: The Hon. Loretta A. Preska District Judge United States District Court for the Southern District of New York (via United States mail) s/ Nicole Simmons 43 EFTA00075525

EFTA00079367 Respectfully submitted, s/ Adam Mueller Ty Gee Adam Mueller HADDON, MORGAN AND FOREMAN

E MAXWELL, Defendant-Appellant. On Appeal from the U.S. District Court for the Southern District of New York No. 15-CV-7433 (LAP) The Honorable Loretta A. Preska, U.S. District Judge On Appeal from the U.S. District Court for the Southern District of New York No. 20-CR-330 (AJN) The Honorable Alison J. N

(true), that it "has never intervened or appeared in the civil suit" (also true), that it "has had no role in the litigation that resulted in Judge Preska's order" (true again), and that it has no "legal interest in the relief Maxwell seeks in the civil case" (true and extraordinarily revealing). Doc.

oner DAppellet/Respondent MOVING ATTORNEY: Adam Mueller [name of attorney, with fon, address, phone numb

-mail) Haddon, Morgan and Foreman, P.C. Boies Schiller & Flexner LLP OPPOSING ATTORNEY: Sigrid McCawley Court- Judge/ Agency appealed from: Hon. Loretta A. Preska, District Judge (S.D.N.Y.) Please check appropriate boxes: Has movant notifiedr oposing counsel (required by Local Rule 27.1): lElYes I [No (expla

VIII (Pages App.-0777 to App.-0852) Ty Gee Adam Mueller HADDON, MORGAN AND FOREMAN, P.C. Attorneys or e

Haddon. Morgan and Foreman. PC Laura A. Menninger www hmacrw tom 2020 Order (Doc. 1096) v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: I write in response to the Court's Order of August 3, 2020 (Doc. 1069), the Order and Protocol for Unsealing Decided Motions (Doc. 1044) ("Protoco