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(USANYS)" alMIE>

From: To: Cc: (USANYS)" alMIE> (USANYS) [Contractor]" <=I=IMIM> Subject: Re: The Spectator - Prince Andrew story Date: Mon, 15 Jun 2020 15:21:57 +0000 Inline-Images: -WRD000.jpg; image001.jpg I'll respond, thanks. Sent from my iPhone On Jun 15, 2020, at 11:18 AM, ME=IIMIM> wrote: From: Matt McDonald Sent: Monday, June 15, 2020 11:12 AM To: Berman, Geoffrey (USANYS) Subject: The Spectator - Prince Andrew story Dear Mr Berman, Mr Our writer Dominic Green has written about Prince Andrew's correspondence with the Southern District of New York, and how it is being characterized by Geoffrey Berman. I was wondering whether you would be prepared to comment on the following excerpts from Mr Green's story. He attempted to contact the press office earlier today but was not able to get through to anyone: 'Berman has actively misled the global media and the global audience, 'my source alleges. 'The Duke's legal team has dozens of email exchanges with the Southern District, pr

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EFTA 00079940
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From: To: Cc: (USANYS)" alMIE> (USANYS) [Contractor]" <=I=IMIM> Subject: Re: The Spectator - Prince Andrew story Date: Mon, 15 Jun 2020 15:21:57 +0000 Inline-Images: -WRD000.jpg; image001.jpg I'll respond, thanks. Sent from my iPhone On Jun 15, 2020, at 11:18 AM, ME=IIMIM> wrote: From: Matt McDonald Sent: Monday, June 15, 2020 11:12 AM To: Berman, Geoffrey (USANYS) Subject: The Spectator - Prince Andrew story Dear Mr Berman, Mr Our writer Dominic Green has written about Prince Andrew's correspondence with the Southern District of New York, and how it is being characterized by Geoffrey Berman. I was wondering whether you would be prepared to comment on the following excerpts from Mr Green's story. He attempted to contact the press office earlier today but was not able to get through to anyone: 'Berman has actively misled the global media and the global audience, 'my source alleges. 'The Duke's legal team has dozens of email exchanges with the Southern District, pr

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From: To: Cc: (USANYS)" alMIE> (USANYS) [Contractor]" <=I=IMIM> Subject: Re: The Spectator - Prince Andrew story Date: Mon, 15 Jun 2020 15:21:57 +0000 Inline-Images: -WRD000.jpg; image001.jpg I'll respond, thanks. Sent from my iPhone On Jun 15, 2020, at 11:18 AM, ME=IIMIM> wrote: From: Matt McDonald Sent: Monday, June 15, 2020 11:12 AM To: Berman, Geoffrey (USANYS) Subject: The Spectator - Prince Andrew story Dear Mr Berman, Mr Our writer Dominic Green has written about Prince Andrew's correspondence with the Southern District of New York, and how it is being characterized by Geoffrey Berman. I was wondering whether you would be prepared to comment on the following excerpts from Mr Green's story. He attempted to contact the press office earlier today but was not able to get through to anyone: 'Berman has actively misled the global media and the global audience, 'my source alleges. 'The Duke's legal team has dozens of email exchanges with the Southern District, proving that there has been full cooperation.' On January 27, Berman denounced the Duke fivm the steps of Epsteinl• Manhattan townhouse. Berman claimed to be facing a 'wall of silence' and 'zero co-operation from Andrew But this, my source tells me, wasn't true: 'Berman must have known we had an email trail.' *** ...the DOJ made no effort to contact Prince Andre lifitime. Only after Epstein's death in August 2019 and the BBC's broadcast of ccusations in November 2019, did the DOJ approach the Prince — not as a suspect, but as a witness. 'The lawyers responded immediately' I'm told. In early January, the Prince's new legal team suggested that they draft a proposal for how Andrew would deliver his witness statement. The DOJ, my source reports, accepted this approach. EFTA00079940 Although the DOJ wanted to talk with Andrew as a witness, Berman seemed to imply that Andrew had aided Epstein's crimes: Epstein couldn't have done what he did without the assistance of others. ' This, I'm told, was an 'overt breach of the DOJ :r own rules on how to engage with witnesses, and the need to maintain privacy and confidentiality'. After Berman's attack in January, there was a every frank exchange of views' between Andrews lawyers and the Southern District. But Andrew's team played by the rules and didn't release emails that would prove they were negotiating with the Southern District in good faith. We plan to publish the story at 3pm ET, but can update the story to include any response. If this request for comment should be directed towards your press office, I'd appreciate it if you could pass it onto them - there is no way of contacting them on the SDNY site as their mailbox is full and no one is in the office. Yours sincerely, Matt McDonald Matt McDonald Managing Editor The Spectator US <image001.jpg> <—WRD000.jpg> EFTA00079941

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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

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