EFTA00075477.txt

"In Brown v. Maxwell, this Court directly released to the public the summary judgment order"

"Take Ms. Maxwell's April 2016 deposition."

"Ms. Maxwell's indictment and arrest"

"on August 10 informed Judge Preska about the existence of the critical new information"

"the entire 418-page transcript of the April 2016 deposition"

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

"On July 2,2020... the government staged a dramatic, forced entry at dawn into her home and arrested her"

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

"the parties agreed to a settlement of the defamation claim, and the case was dismissed"

"LORETTA A. PRESKA, Senior United States District Judge... 15 Civ. 7433 (LAP)"

"GHISLAINE MAXWELL, Defendant... 15 Civ. 7433 (LAP)"

"individuals associated with Jeffrey Epstein--a group that, of course, includes Ms. Maxwell"

"Ms. Maxwell's right to seek relief in the criminal case... Case 20-2413"

"the deposition proceeded as scheduled the next day... Ms. Maxwell's April 2016 deposition"

"Ms. Maxwell's request for reconsideration of the Court's July 23 ruling is accordingly denied."

"GHISLA1NE MAXWELL, Defendant-Appellant"

"The government has indicted Ghislaine Maxwell. In the criminal case, 20 Cr. 330"

"HADDON, MORGAN AND FOREMAN, P.C. ... Attorneys for Defendant-Appellant Ghislaine Maxwell"

"Adam Mueller... Counsel for Defendant-Appellant Ghislaine Maxwell"

"Ty Gee... Counsel for Defendant-Appellant Ghislaine Maxwell"

"Adam Mueller HADDON, MORGAN AND FOREMAN, P.C."

"Ty Gee... HADDON, MORGAN AND FOREMAN, P.C."

"Counsel for Defendant-Appellant Ghislaine Maxwell"

"HADDON, MORGAN, AND FOREMAN, P.C. Attorney for Defendant BY: LAURA A. MENNINGER"

"HADDON, MORGAN, AND FOREMAN, P.C. Attorney for Defendant"

"v. 15 CV 7433 (LAP) GHISLAINE MAXWELL, Defendant"

"Before: HON. LORETTA A. PRESKA, District Judge"

"correspondence released in the case between Ms. Maxwell and Jeffrey Epstein from January 2015"

"motion to join in Jane Doe 1 and Jane Doe 2 files in court"

"motion to join in Jane Doe 1 and Jane Doe 2 files in court"

"Plaintiff filed with the district court the entire 418-page transcript... Ms. Maxwell's reliance interests, and those of Doe 1"

"The deposition material at issue here... as this Court found in Brown"

"Judge Preska —who is presiding over the civil case and the litigation about the unsealing of the district court filings"

"a protective order in the criminal case, entered by Judge Nathan"

"Judge Sweet made factual findings on exactly this point"

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

"Ms. Maxwell intends to make that argument to Judge Nathan in the criminal case"

"if Judge Preska's unsealing order is affirmed"

"Only after the briefing was concluded was Ms. Maxwell indicted, arrested, and held without bond"

"The defamation action... alleged that Ms. Maxwell defamed her."

"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"

"Doe 1's deposition transcript as well as numerous sealed or redacted orders"

"the district court denied a motion filed by Alan Dershowitz to modify the Protective Order 'to permit him access to all filings and discovery material"

"Counsel for plaintiff originally proposed protective order language... Bradley Edwards opined"

"Counsel for plaintiff... Sigrid McCawley praised the prosecutors"

"Ms. Maxwell's concern that unsealing would 'inappropriately influence potential witnesses or alleged victims,' (id.), and her reference to... Ms. Maxw"

"Ms. Maxwell's concern... and her reference to 'publicly reported statements by... the United States Attorney for the Southern District of New York... "

"Ms. Maxwell's concern... and her reference to 'publicly reported statements by... the Attorney General for the U.S. Virgin Islands' about those invest"

"Ty Gee Adam Mueller HADDON, MORGAN AND FOREMAN, P.C. ... Attorneys for Defendant-Appellant Ghislaine Maxwell"

"Ty Gee Adam Mueller HADDON, MORGAN AND FOREMAN, P.C. ... Attorneys for Defendant-Appellant Ghislaine Maxwell"