m: Sent: Friday, July 31, 2020 22:51 To: Subject: Unsealing I didn't realize Maxwell's deposition is being unsealed in the litigation before Judge Preska. Is that right? I saw an article suggesting that will be released in the batch of documents, but wasn't sure. is named in it, obviously, so that r

their motion to modify the protective order, they will appeal to the Second Circuit and seek consolidation of that appeal with the appeal from Judge Preska's order. From: Sigrid McCawley Sent: Thursday, August 20, 2020 8:27 PM To: `: "; 1S , Subject: FW: New document v. Maxwell (Doc* -, 2d Cir. 20-

OF COURT Date: October 19, 2020 DC Docket #: 15-cv-7433 Docket #: 20-2413cv DC Court: SDNY (NEW YORK Short Title: v. Maxwell CITY) DC Judge: Preska BILL OF COSTS INSTRUCTIONS The requirements for filing a bill of costs are set forth in FRAP 39. A form for filing a bill of costs is on the Court

. 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 Unsealing Decided Motions (Doc. 1044) ("Protoco

("the Unsealing Materials") in two, settled, civil matters in which Ms. Maxwell was named a defendant. These materials would be disclosed to Judge Preska and designated as part of the appendix to Ms. Maxwell's appeal in the Second Circuit. We have no objection, at this point, to filing the materials

their confidential information, and implementing a protocol for maintaining or unsealing the sealed status of thousands of pages of material. Judge Preska sought input from the various Does, the lawyers for primarily Sigrid McCawley, a partner at BSF, and counsel for Ms. Maxwell. Judge Preska was obli

ability analysis in this case," however, "is predicated on an assessment of the actions that might have been taken by third parties," such as Judge Preska and the Miami Herald, who are "not acting at the behest of the police." Id. "Such an analysis is inherently speculative." Id. In fact, unlike every

that you filed under seal (Exhibit H). We understand that the quoted portions of that document are also under seal on the civil docket before Judge Preska. Given those facts, we wanted to double check with you to see whether you in fact want those redactions removed. We will defer to you on whether the

that you filed under seal (Exhibit H). We understand that the quoted portions of that document are also under seal on the civil docket before Judge Preska. Given those facts, we wanted to double check with you to see whether you in fact want those redactions removed. We will defer to you on whether the

ia.cominews/politics/2020/01/23/ghisla i ne-maxwell s-lawyers-adm it-they-dont-know- where-she-is-either/), which refers to a letter filed with Judge Preska in January 2020, and dated December 2019. The article claims that the letter admitted Maxwell's lawyers don't know where their client is. Maxwell's

www.hmtlaw.com tgeefghmflaw.com Re: Reconsideration of the Court's July 23 Ruling Giuffre v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its Protective Order and punish its violation. Ms. Maxwell's two depositio

cale; on another scale probability of deception is less than .01 and probably of deception on another scale was less than .001 • August 2019 —Judge Preska unsealed passages from • May 3, 2016 deposition in which • named BR as person GM directed her to have sex with • "Catastrophic" impact on reputati

tta A. Preska allowed Dershowitz's motion to be reinstated and said he could file a 28-page memo on his request. The order comes a week after Judge Preska said she was removing the motion because Dershowitz didn't request a premotion conference before the filing in violation of a court rule. Dershowit

— because of a strong expectation of continued confidentiality. 929 F.3d 4, 48, n.22 (2d Cir. 2019) (citing Fed. R. Civ. P. 5.2). So, too, has Judge Preska redacted substantial material from the documents she has released on remand from the Second Circuit, again reflecting that Maxwell reasonably relied

d— because of a strong expectation of continued confidentiality. 929 F.3d 4, 48, 122 (2d Cir. 2019) (citing Fed. R. Civ. P. 5.2). So, too, has Judge Preska redacted substantial material from the documents she has released on remand from the Second Circuit, again reflecting that Maxwell reasonably relied

on at Pages 129-134 The government proposes, at pages 129-134, to redact only certain portions of Ms. Maxwell's sealed deposition testimony. Judge Preska has ruled that certain questions and answers are still under seal and subject to the Protective Order in the case. In Ms. Maxwell's Motions, we li

that right, most especially in light of media coverage and the debacle that occurred during a remote proceeding in a related civil case before Judge Preska. In addition, Ms. Maxwell is requesting a bail hearing at which witnesses will testify regarding the purported strength of the government's case. F

tta A. Preska allowed Dershowitz's motion to be reinstated and said he could file a 28-page memo on his request. The order comes a week after Judge Preska said she was removing the motion because Dershowitz didn't request a premotion conference before the filing in violation of a court rule. Dershowit