Epstein Secrets

Motion to Stay Pending Appeal or, in the Alternative, Motion for a Temporary Administrative Stay Pending Full Consideration of the Motion to Stay Ty Gee Laura Menninger Adam Mueller Z1LLUI JW llyt/Gtialtt Llftt-1lLttliG EFTA00074904 Case 20-2413. Document 10-1, 07/30/2020, 2896538, Page3 of 38

which they may have refused to testify. . . . [T]he witnesses were entitled to rely upon the terms of a concededly valid protective order and Judge Conner did not abuse his discretion in refusing to vacate or modify that order. Id. at 296-97. Three, the government did not obtain a copy of the deposit

oretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, r.0 Ty Gee 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 HI 303.832.2628 www.hmtlaw.com [email protected] Re: Reconsideration of the Court's Jul

nt which they may have refused to testify.... [T]he witnesses were entitled to rely upon the terms of a concededly valid protective order and Judge Conner did not abuse his discretion in refusing to vacate or modify that order. Id at 296-97. Three, the government did not obtain a copy of the depositi

oretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, P C Ty Gee 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 HI 303.832.2628 www.hmllaw.com [email protected] Re: Reconsideration of the Court's Jul

nt which they may have refused to testify.... [T]he witnesses were entitled to rely upon the terms of a concededly valid protective order and Judge Conner did not abuse his discretion in refusing to vacate or modify that order. Id at 296-97. Three, the government did not obtain a copy of the depositi

nt which they may have refused to testify.... [T]he witnesses were entitled to rely upon the terms of a concededly valid protective order and Judge Conner did not abuse his discretion in refusing to vacate or modify that order. M at 296-97. Three, the government did not obtain a copy of the depositio

and Doe l's depositions, and (2) court submissions excerpting from, quoting from or summarizing the contents of the transcripts. Very truly yours, Ty Gee C: Counsel of Record via ECF EFTA00021869