EFTA00018749.pdf

"Defendant Ghislaine Maxwell ... requests that the Court enter an Order ... Counsel for Ms. Maxwell"

"Haddon, Morgan and Foreman, t.c Jeffrey Paglloca"

"The Honorable Alison J. Nathan ... United States v. Ghislaine Maxwell, 20 Cr. 330 (MN)"

"In 2015, alleged in a civil suit that Ms. Maxwell defamed her ... Giuffre v. Maxwell, 15-cv-7433"

"On January 26, 2017, plaintiff Jane Doe 43 sued various individuals including Ms. Maxwell."

"Jane Doe 43 also was represented by BSF, the same lawyers who represent [Giuffre]"

"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"

"Sigrid McCawley, a partner at BSF"

"Chief Judge McMahon"

"Chief Judge McMahon had already granted an ex pane request from the government to obtain Ms. Maxwell's deposition"

"Magistrate Judge Netburn"

"August 17, 2020 VIA EMAIL The Honorable Alison J. Nathan ... Dear Judge Nathan"

"the government served BSF with a subpoena to produce (apparently) all the BSF litigation files pertaining to both civil litigations."

"Counsel for Ms. Maxwell then learned, on August 14, 2020, that BSF has produced 90,000 pages of discovery from BSF, including their entire civil file"

"On July 8, the government filed a superseding indictment alleging that Ms. Maxwell assisted, facilitated, and contributed to Epstein's abuse of minors"

"Judge McMahon... granted the ex pane application."

"Magistrate Judge Netburn denied the application."

"Judge Preska has jurisdiction over the Protective Order entered in the Giuffre v. Maxwell case."

"Letter of Alex Rossmiller at 6 (Doc. # 33)"

"In the Giuffre v. Maxwell litigation"

"Respectfully Submitted, Je rey S. Pagliuca"

"See Giuffre v. Maxwell, 15-cv-7433 (Doc. # 1100)."

"See Giuffre v. Maxwell, 15-cv-7433 (Doc. # 1100)."

"On August 12, Judge Preska denied the motion to stay, finding that: Given that Ms. Maxwell is not at liberty to disclose this new information"

"Ms. Maxwell's July 2016 deposition, also sealed and a part of the indictment in this case."

"the Court has no reasonable basis to impose a stay. See Giuffre v. Maxwell, 15-cv-7433 (Doc. # 1103) Unless this Court modifies the Protective Order, "

"refer to and file under seal in Giuffre v. Maxwell, 15-cv-5433 (LAP), and the related Second Circuit appeal, Giuffre v. Maxwell, No. 20-2413"

"allegations that Ms. Maxwell participated in a scheme causing her to be sexually abused and trafficked by Jeffrey Epstein"

"Boies Schiller & Flexner ... which appears to include their entire civil file from the Giuffre case ... lawyers for [Giuffre] primarily Sigrid McCawle"

"The Honorable Alison J. Nathan"

"Boies, Schiller & Flexner ("BSF') lawyers, cooperating with the government, are aware of the Material."

"alleging that Ms. Maxwell assisted, facilitated, and contributed to Epstein's abuse of minors."

"This concern is all the more real when one law firm, BSF, is in possession of these sealed materials representing accusers who may be witnesses in thi"