Exhibit H
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Exhibit H EFTA00065769 29 October, 2020 The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, NY 10007 Your Honor: This statement is in support of Ghislaine Maxwell's request for bail and her character. I have known Ghislaine since witnessed her develop into a lovely, energetic and capable young woman. and and the importance of key moral values and conciseness" Ghislaine, also learned a relentless work ethic such as "concentration, consideration • Though Ghislaine left the United Kingdom for America we have always remained closed and kept in contact. I know that many of and their friends have visited and benefitted from staying with Ghislaine during their vacations and for life experience over the years, and Ghislaine asked ifs MUM would like to come over for a few months after she finished university . It was a EFTA00065770 kind and generous invitation from her and we h
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Ca_4ate.24h24/43134.01FrietibtOrtlefifitin0a0le28013,8111$2eafiabef146f 22
Ca_4ate.24h24/43134.01FrietibtOrtlefifitin0a0le28013,8111$2eafiabef146f 22 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Reply In Support Of Iler Objections to tnsealinu Sealed Materials Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue EFTA00074964 Ca_QatIgt24743tictoWneDbtOrfiefiVIMOXIle?BOWERKVaffizte12401 22 Introduction This Court asked the parties to brief three issues: "(a) the weight of presumption of public access that should be afforded to an item, (b) the identification and weight of any countervailing interests supporting continued sealing/redaction of the item, and (c) whether the countervailing interests rebut the presumption of public access to the item." DE 1044 at 1. Plaintiff and the Miami Herald's responses improperly afford the highest level of presumption to discovery dispute documents, deny that any co
Case 20-2413. Document 40. 08'20/2020. 2913550, Pagel of 74
Case 20-2413. Document 40. 08'20/2020. 2913550, Pagel of 74 20-2413 United States Court of Appeals for the Second Circuit Plaintlff-Appelke, —against— GHISLA1NE MAXWELL, Defendant-Appellant, SHARON CHURCHER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNOVICH MEDIA Intervenors. ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, 15-CV-7433 (LAP) Ghislaine Maxwell's Opening Brief Ty Gee Adam Mueller HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Den r 2 Tel. Attorneys for Defendant-Appellant Ghislaine Maxwell EFTA00075477 Case 20-2413, Document 40, 08/20/2020, 2913550, Page2 of 74 Table of Contents Table of Authorities iii Introduction 1 Jurisdictional Statement 2 Issues Presented 3 Statement of the Case and the Facts 3 The defamation action and the Protective Order 3 The motion to unseal and the first appeal 6 The remand, the arrest,
LBUCmaxl
120 LBUCmaxl UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. Before: 20 CR 330 (AJN) Jury Trial New York, N.Y. November 30, 2021 8:50 a.m. HON. ALISON J. NATHAN, APPEARANCES DAMIAN United States Attorney for the Southern District of New York BY: Assistant United States Attorneys HADDON MORGAN AND FOREMAN Attorneys for Defendant BY: JEFFREY S. PAGLIUCA CHRISTIAN R. EVERDELL LAURA A. MENNINGER -and- BOBBI C. STERNHEIM -and- RENATO STABILE Also Present: District Judge , FBI NYPD Sunny Drescher, Paralegal, U.S. Attorney's Office Ann Lundberg, Paralegal, Haddon Morgan and Foreman SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068582 121 LBUCmaxl 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Jury not present) THE COURT: Looks like we have everybody. Matt
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY PILED DOC 0: DATE FILED:i 102121 20-CR-330 (AJN) MEMORANDUM OPINION & ORDER ALISON J. NATHAN, District Judge: The Defense on November 1, 2021, noticed eight expert witnesses. Def. Br., Ex. 1 ("Notice"). Two of those experts, Dr. Park Dietz and Dr. Elizabeth Loftus, are expected to offer opinions that rebut opinions of the Government's expert witness, Dr. Lisa Rocchio. The Government on November 8, 2021, filed a motion to partially preclude the testimony of Dr. Dietz and Dr. Loftus. Dkt. No. 424. The Court has already addressed that motion. On November 15, 2021, the Government moved to fully or partially preclude the testimony of the remaining six experts. The Defense filed a response on November 19, 2021. The Court addresses the motion to preclude Dr. Hall in this separate opinion. It will address the other five e
(USANYS)'
From: (USANYS)' To: " CRM" II II Cc: " (CRM)" Subject: R -: n epee ent: Prince n rew: e sa to to to Epstein investigators 'straining relations between UK and America' Date: Thu, 12 Aug 2021 12:58:39 +0000 lane-Images: image001.png Thanks, The below looks good to us. On the penalties: Title 18, United States Code, Section 2423 (transportation of minors) — maximum penalty is 10 years' imprisonment Title 18, United States Code, Section 2422 (coercion and enticement) — maximum penalty is 5 years' imprisonment Title 18, United States Code, Section 1591 (sex trafficking) — maximum penalty is 40 years' imprisonment From: (CRM) Sent: Thursday, August 12, 2021 5:49 AM (USANYS) C (CRM) Subject: RE: Independent: Prince Andrew: Refusal to talk to Epstein investigators 'straining relations between UK and America' We also just got the following questions on the new MLA request. I have given preliminary responses (as noted), but want to confirm with you. I. Has the witne
Subject: DAILY BEAST; How Did !rump and Clinton Pal Jeffrey Epstein Escape #Me loot
From: To: Cc: Subject: DAILY BEAST; How Did !rump and Clinton Pal Jeffrey Epstein Escape #Me loot Date: Fri, 22 Jun 2018 20:08:44 +0000 Importance: Normal How Did Trump and Clinton Pal Jeffrey Epstein Escape #MeToo? Call him Weinstein 1.o: The billionaire with famous friends (Kevin Spacey, Woody Allen) was a secret pervert who used his power and influence to groom teens for abuse. As the Harvey Weinsteins of the world get their comeuppance in the press and in court, another serial predator walks free. Last month, after a flood of allegations by Hollywood actresses, Weinstein was indicted on rape and criminal sex act charges in New York. The disgraced Hollywood executive stands accused of assaulting one woman in 2004 at Miramax headquarters in TriBeCa and raping another woman at a Midtown hotel nine years later. He has pleaded not guilty to these crimes. Since Weinstein's reign of terror was exposed and ignited a #MeToo reckoning other powerful men have found themselves
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