EFTA00018749Set 8
2020-08-178p3,922w
filed ("the Material") are not confidential and disclosure
confined to the Honorable Loretta Preska and the Second Circuit Court of Appeals, under seal,
' Ms. Maxwell seeks leave to file this ... unsealing process.
On July 9, the Giuffre case was assigned to the Honorable Loretta Preska who was charged with
the difficult and time consuming task of sorting through thousands ... 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
https://www.justice.gov/epstein/files/DataSet%208/EFTA00018749.pdf
EFTA00075477Set 9
2020-08-2074p15,469w
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 ... August 7 reviewed the government's disclosure and on August 10 informed Judge
Preska about the existence of the critical new information. App. p 787.
At the time, however ... criminal case, entered by
Judge Nathan, prevented Ms. Maxwell from informing Judge Preska about the
nature of the new information. App. pp 787,791-802. The same protective order
https://www.justice.gov/epstein/files/DataSet%209/EFTA00075477.pdf
EFTA00094804Set 9
2020-07-299p4,346w
FOREMAN PH 303.831.7364 HI 303.832.2628
www.hmtlaw.com
tgee@hmflaw.com
July 29, 2020
Honorable Loretta A. Preska
United States District Court
Southern District of New York
500 Pearl Street
New York ... July 23 Ruling
Giuffie 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 ... Document 1078 Filed 07/29/20 Page 2 of 9
Honorable Loretta A. Preska
July 29, 2020
Page 2
courts have recognized, temporary stays of unseal orders are appropriate so that
https://www.justice.gov/epstein/files/DataSet%209/EFTA00094804.pdf
EFTA00021861Set 8
2020-07-299p4,346w
FOREMAN ni 303.831.7364 rx 303.832.2628
www.hmtlaw.com
tgeefghmflaw.com
July 29, 2020
Honorable Loretta A. Preska
United States District Court
Southern District of New York
500 Pearl Street
New York ... 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 ... Document 1078 Filed 07/29/20 Page 2 of 9
Honorable Loretta A. Preska
July 29, 2020
Page 2
courts have recognized, temporary stays of unseal orders are appropriate so that
https://www.justice.gov/epstein/files/DataSet%208/EFTA00021861.pdf
EFTA00076383Set 9
2016-04-2178p17,141w
Plaintiff,
No. 15 Civ. 7433 (LAP)
-against-
MEMORANDUM & ORDER
GHISLAINE MAXWELL,
Defendant.
LORETTA A. PRESKA, Senior United States District Judge:
The Court has reviewed Defendant Ghislaine Maxwell's letter
requesting ... ORDERED.
Dated: New York, New York
July 29, 2020
eZdzat.fo? Yadeitig
LORETTA A. PRESKA
Senior United States District Judge
4
EFTA00076388
CaseastE2812€171431NARnedxgrai rAil CEilikl 87 RagEfragt7Bof ... Menninger
HADDON
M ORGAN
FOREMAN www hmacrw tom
August 10, 2020
Honorable Loretta A. Preska
United States District Court
Southern District of New York
500 Pearl Street
New York
https://www.justice.gov/epstein/files/DataSet%209/EFTA00076383.pdf
EFTA00097649Set 9
2014-10-2420p4,543w
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 ... Maxwell docket and has not been unsealed by Judge Preska. Resp. at 94. In fact, the
government's response appears to concede that its inevitable discovery argument is limited ... government recognizes, Judge Preska recognized this possibility, but deferred to this
Court on the question since it is presiding over the criminal case. Resp. at 94 n.41.
6
EFTA00097659
Maxwell
https://www.justice.gov/epstein/files/DataSet%209/EFTA00097649.pdf
EFTA00100287Set 9
2014-10-2420p4,646w
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 ... Giuffre v. Maxwell docket and has not been unsealed by Judge Preska. Resp. at 94. In fact, the
government's response appears to concede that its inevitable discovery argument ... limited to
' As the government recognizes, Judge Preska recognized this possibility, but deferred to this
Court on the question since it is presiding over the criminal case. Resp
https://www.justice.gov/epstein/files/DataSet%209/EFTA00100287.pdf
EFTA00097331Set 9
2014-10-2420p4,558w
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 ... Maxwell docket and has not been unsealed by Judge Preska. Resp. at 94. In fact, the
government's response appears to concede that its inevitable discovery argument is limited ... government recognizes, Judge Preska recognized this possibility, but deferred to this
Court on the question since it is presiding over the criminal case. Resp. at 94 n.41.
6
EFTA00097341
Maxwell
https://www.justice.gov/epstein/files/DataSet%209/EFTA00097331.pdf
EFTA00018997Set 8
2014-10-2420p4,647w
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 ... Giuffre v. Maxwell docket and has not been unsealed by Judge Preska. Resp. at 94. In fact, the
government's response appears to concede that its inevitable discovery argument ... limited to
' As the government recognizes, Judge Preska recognized this possibility, but deferred to this
Court on the question since it is presiding over the criminal case. Resp
https://www.justice.gov/epstein/files/DataSet%208/EFTA00018997.pdf
EFTA01658246Set 10
2020-07-3043p25,293w
morning, Maxwell's lawyers filed a motion to
reconsider before U.S. District Judge Loretta Preska, challenging her July 23 decision to order
EFTA01658262
the unsealing and release of documents ... case brought by Epstein accuser Virginia Giuffre. Less than three hours later,
Preska denied it, citing `eleventh-hour request for reconsideration.' She allowed Maxwell's
attorneys two days to seek ... lawsuit, alleging the transcripts were leaked illegally to prosecutors seeking her conviction."
Judge Preska "gave Maxwell's lawyers until Friday to appeal" her Wednesday ruling. The Post
adds
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01658246.pdf
EFTA00136262Set 9
2020-07-3051p25,800w
morning, Maxwell's lawyers filed a motion to reconsider
before U.S. District Judge Loretta Preska, challenging her July 23 decision to order the unsealing and release of
documents ... case brought by Epstein
accuser Virginia Giuffre. Less than three hours later, Preska denied it, citing `eleventh-hour request for
reconsideration.' She allowed Maxwell's attorneys two days to seek ... lawsuit, alleging the transcripts were leaked illegally to prosecutors seeking her conviction."
Judge Preska "gave Maxwell's lawyers until Friday to appeal" her Wednesday ruling. The Post adds
https://www.justice.gov/epstein/files/DataSet%209/EFTA00136262.pdf
EFTA00150335Set 9
2020-07-3043p25,250w
morning, Maxwell's lawyers filed a motion to
reconsider before U.S. District Judge Loretta Preska, challenging her July 23 decision to order
the unsealing and release of documents ... case brought by Epstein accuser Virginia Giuffre. Less than three hours later,
Preska denied it, citing `eleventh-hour request for reconsideration.' She allowed Maxwell's
attorneys two days to seek ... lawsuit, alleging the transcripts were leaked illegally to prosecutors seeking her conviction."
Judge Preska "gave Maxwell's lawyers until Friday to appeal" her Wednesday ruling. The Post
adds
https://www.justice.gov/epstein/files/DataSet%209/EFTA00150335.pdf
EFTA00018580Set 8
2020-08-103p1,360w
Menninger
HADDON
Denver, Colorado 80203
MORGAN
FOREMAN wvow.hmilaw.com
August 10, 2020
Honorable Loretta A. Preska
United States District Court
outhern District of New York ... 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 ... Document 1100 Filed 08/10/20 Page 2 of 3
Honorable Loretta A. Preska
August 10, 2020
Page 2
Ms. Maxwell requests a temporary stay of the unsealing process for approximately
three
https://www.justice.gov/epstein/files/DataSet%208/EFTA00018580.pdf
EFTA00088205Set 9
2020-08-246p2,973w
today.
But Ms. Maxwell is seeking in both the Second Circuit and before Judge Preska that the status
quo be maintained until the issue can be litigated. If, for example ... without the benefit of this
information, the Second Circuit and/or Judge Preska order Ms. Maxwell's deposition unsealed,
the cat will be out of the bag. Should this Court ultimately ... ongoing criminal
investigation to reveal the sealed materials under seal to two arbiters: Judge Preska and the
Second Circuit panel assigned to the unsealing process. Clearly those judicial officers
https://www.justice.gov/epstein/files/DataSet%209/EFTA00088205.pdf
EFTA00095335Set 9
2020-09-118p1,448w
distinct district court proceedings, the only issue in the civil
appeal is whether Judge Preska abused her discretion in ordering certain judicial
documents unsealed pursuant to the public's right ... specificity.
App. 777 ("Ms. Maxwell's eleventh-hour request for reconsideration is denied."
(Preska, J.)); it at 803-04 ("And, as Ms. Maxwell knows, her ipse dixit does not
provide ... compelling grounds for relief." (Preska, J.)); D.E. 102 at 3 ("But after
3
EFTA00095338
fourteen single-spaced pages of heated rhetoric, the Defendant proffers no more than
vague, speculative
https://www.justice.gov/epstein/files/DataSet%209/EFTA00095335.pdf
EFTA00084609Set 9
2020-08-103p1,371w
MORGAN
Pll 303.831.7364 EX 303.832.2628
FOREMAN www.hmtlaw.com
LMenninger4hrntlaw.com
August 10, 2020
Honorable Loretta A. Preska
United States District Court
Southern District of New York
500 Pearl Street
New York ... 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 ... Document 1100 Filed 08/10/20 Page 2 of 3
Honorable Loretta A. Preska
August 10, 2020
Page 2
Ms. Maxwell requests a temporary stay of the unsealing process for approximately
three
https://www.justice.gov/epstein/files/DataSet%209/EFTA00084609.pdf
EFTA00077108Set 9
2020-08-103p1,371w
MORGAN
PH 303.831.7364 EX 303.832.2628
FOREMAN
www.hmtlaw.com
LMenningergthrntlaw.com
August 10, 2020
Honorable Loretta A. Preska
United States District Court
Southern District of New York
500 Pearl Street
New York ... 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 ... Document 1100 Filed 08/10/20 Page 2 of 3
Honorable Loretta A. Preska
August 10, 2020
Page 2
Ms. Maxwell requests a temporary stay of the unsealing process for approximately
three
https://www.justice.gov/epstein/files/DataSet%209/EFTA00077108.pdf