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Casese Ace QGISSOOAUN ES GourMArtA1 70 iA PEP AIH) 20 ageye Al dP18
abuse of minor victims by Jeffrey Epstein, including some of the
specific events and acts of abuse detailed above.
STATUTORY ALLEGA
9/18/2020 Case 20-3061, Document 64pWiGReO2OcetB@82802 Page13 of 125
08/20/2020 50 | SEALED DOCUMENT placed in vault. (mhe) (Entered: 08/27/2020)
08/21/2020 46
08/21/2020 47
08/24/2020 48
08/25/2020
9/18/2020
Case 20-3061, Document 64pWiG7ReO2OcetB@s82802 Paget4 of 125
Reply in Support of Request to Modify Protective Order. (jbo) (Entered: 09/08/2020)
09/09/2020
09/09/2020
Transmission of No
9/18/2020 Case 20-3061, Document 64pmiG7ReO2OcetB@82802 Paget2 of 125
criminal matters that had related civil litigation. The Government labors under many
restrictions including Rule 6(e) of the Fede
9/18/2020 Case 20-3061, Document 64pmiG7ReO2OceB@82802 Page10 of 125
and messages from non-parties that purport to be related to this case. These submissions
are either procedurally improper or irrel
9/18/2020 Case 20-3061, Document GbNOSKHAZEe NkRser 95Ea980, Paged of 125
Terminated Counts Disposition
None
Highest Offense Level (Terminated)
None
Complaints Disposition
None
Plaintiff
USA r
Case 20-3061, Document 61, 09/24/2020, 2938280, Page2 of 125
Table of Contents
Docket Sheet .0.........:cesseescseeseesseeeseeeseeceeeeesceesaeesaceeseeesaeeeaeeeeeesaeeeaeessaeeseeeeas 001-012
017 S
9/18/2020 Case 20-3061, Document GbNOSKHAZE NGser 95Ea80, Page3 of 125
Query’ Reports Utilities Help Log Out
APPEAL,ECF
U.S. District Court
Southern District of New York (Foley Square)
CRIMINAL DOCK
Case 20-3061, Document 61, 09/24/2020, 2938280, Page1 of 125
20-3061
United States Court of Appeals
for the Second Circuit
UNITED STATES OF AMERICA
Plaintiff-Appellee,
— against —
GHISLAINE MAXWEL
Case C2@-G0-00484-DGHUDER ODoeHékGA, PREG DL21 H2GeDRanfedss of 13
out, both the Indictment in the criminal case and the Complaint in this action contain allegations
that Maxwell “groomed” minor vict
Case C2@-A0-00484-DGtuUDER ODoeAékGA, PREG DLI1 H2gQePavfeds of 13
I. MAXWELL’S MOTION FOR A STAY
A. Applicable Legal Standards
Although staying a civil action pending the completion of a criminal pr
Case Ce2@-A0-00484-DGtUDER ODoeHékGA, PREG DLI1 H2ge4Panfed4 of 13
resources; and that those interests [would] outweigh any delay or disruption caused to the
resolution of this civil action.” (/d., a
Case C2@-A0-00484-DGtUDER ODobeHékGA0, PREG DLI1 H2ge4Panfed2 of 13
2020, Maxwell filed the letter motion that is now before this Court, requesting a stay of this
action until the conclusion of her p
Case Ce2@-A0-00484-DGtUDER ODobeHékGA, PREG DL21 Hage4anedss of 13
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
JANE DOE,
Plaintiff 20cv00484 (JGK) (DF)
‘ast MEMORANDUM
“agalnst- AND O
Cases: 20-60603B0AuNenDoCuiwAd 2D 26128 Bw Oa/ 20a gk agent aH
USDC SDNY
DOCUMENT |
ELECTRONICALLY FILED
DOC #:
UNITED STATES DISTRICT COURT DATE FILED:__ 9/2/20
SOUTHERN DISTRICT OF NEW YORK
Unite
Case 20-3061, Document 60, 09/24/2020, 2938278, Page38 of 58
Martindell, 594 F.2d at 296. But unless Judge Nathan’s order is reversed in the
criminal case, Ms. Maxwell cannot share this information w
Case 20-3061, Document 60, 09/24/2020, 2938278, Page37 of 58
Fina,
And it shows that Judge Preska erred failing even to acknowledge or address Ms.
Maxwell’s reliance argument. Giuffre v. Maxwell, Ca
Case 20-3061, Document 60, 09/24/2020, 2938278, Page36 of 58
In Giuffre v. Maxwell, Ms. Maxwell elected not to invoke her Fifth
Amendment privilege against self-incrimination in reliance on the civil
Case 20-3061, Document 60, 09/24/2020, 2938278, Page34 of 58
compromises Ms. Maxwell’s ability to seek a stay of the unsealing process and
thereby safeguard her right to a fair trial in the criminal
Case 20-3061, Document 60, 09/24/2020, 2938278, Page31 of 58
Giuffre v. Maxwell unseal proceedings, into which Ms. Maxwell seeks to introduce
criminal protective order-sealed information relevant to
Case 20-3061, Document 60, 09/24/2020, 2938278, Page28 of 58
opportunity to reevaluate her decision in light of this information, Ms. Maxwell
may never be able to challenge in the criminal case the g
Case 20-3061, Document 60, 09/24/2020, 2938278, Page26 of 58
Roman Catholic Diocese of Albany, N.Y., 745 F.3d 30, 35 (2d Cir. 2014). All three
conditions exist here.
First, as elaborated below, Judg
Case 20-3061, Document 60, 09/24/2020, 2938278, Page24 of 58
preserve the status quo and protect Ms. Maxwell’s right to litigate
Martindell and the Fifth Amendment in the criminal proceeding.
Giuffr
Case 20-3061, Document 60, 09/24/2020, 2938278, Page18 of 58
the collateral order doctrine, particularly when there is no serious argument that it
satisfies each of the doctrine’s three requirements:
Case 20-3061, Document 60, 09/24/2020, 2938278, Page17 of 58
civil case was on appeal and pending before this Court.* Brown v. Maxwell, No. 18-
2868. All Ms. Maxwell asks is for permission to share,
Case 20-3061, Document 60, 09/24/2020, 2938278, Page15 of 58
Jurisdictional Statement
This Court has jurisdiction under the collateral order doctrine to review a
district court decision declining to
Case 20-3061, Document 60, 09/24/2020, 2938278, Page14 of 58
Judge Nathan denied the motion to modify, though she invited Ms. Maxwell
to seek relief from two other judicial officers, xs
PS App. 99-
Case 20-3061, Document 60, 09/24/2020, 2938278, Page of 58
20-3061
United States Court of Appeals
for the Second Circuit
UNITED STATES OF AMERICA
Plaintiff-Appellee,
—against—
GHISLAINE MAXWELL,
D
Case 20-3061, Document 60, 09/24/2020, 2938278, Page3 of 58
ATTACHMENT A, United States »v. Maxwell, No. 20-cr-330, ECF Dkt. 51, Order
Denying Motion to Modify Protective Order
ATTACHMENT B, Doe v.
Case 20-3061, Document 54, 09/23/2020, 2937091, Page3 of 6
case and to stay the unsealing process, just as it moved to intervene and to stay
discovery in Doe v. Indyke, a civil case in which Jane Doe
Case 20-3061, Document 54, 09/23/2020, 2937091, Page6 of 6
Certificate of Compliance with Rule 32(g)
Counsel hereby certifies that this response brief complies with the type-
volume limitation of Fe
Case 20-3061, Document 54, 09/23/2020, 2937091, Page4 of 6
the Government’s applications to modify certain protective orders in other judicial
proceedings.” Ms. Maxwell’s point is that, unless the un
Case 20-3061, Document 54, 09/23/2020, 2937091, Page1 of 6
Nos. 20-2413 &
20-3061
United States Court of Appeals
for the Second Circuit
VIRGINIA L. GIUFFRE,
Plaintiff-Appellee,
V.
GHISLAINE MAXWEL
Case 20-3061, Document 43, 09/16/2020, 2932466, Page‘ of 2
UNITED STATES COURT OF APPEALS
FOR THE
SECOND CIRCUIT
At a Stated Term of the United States Court of Appeals for the Second Circuit, held
Case 20-3061, Document 38, 09/16/2020, 2932233, Page21 of 23
any legal objections to the Government’s evidence before Judge Nathan, who is
presiding over the criminal case. If Maxwell is dissatisfied
Case 20-3061, Document 38, 09/16/2020, 2932233, Page20 of 23
these reasons alone, the Court should deny Maxwell’s motion to consolidate these
appeals.
27. Maxwell has filed two separate appeals chal
Case 20-3061, Document 38, 09/16/2020, 2932233, Page22 of 23
for this Court to adjudicate regarding Judge Nathan’s Order — the lone Order on
appeal in this matter — if the Court were to grant Maxwell
Case 20-3061, Document 38, 09/16/2020, 2932233, Page23 of 23
CERTIFICATE OF COMPLIANCE
Pursuant to Federal Rule of Appellate Procedure 32(g), the undersigned counsel
hereby certifies that this motio
Case 20-3061, Document 38, 09/16/2020, 2932233, Page19 of 23
was founded on the principle that when intervenors seek access to sealed records,
“orders denying access are final as to the intervenors.”
Case 20-3061, Document 38, 09/16/2020, 2932233, Page18 of 23
the appellate courts do not repeatedly intervene to second-guess prejudgment
rulings.” Mohawk, 558 U.S. at 106 (alterations in original) (
Case 20-3061, Document 38, 09/16/2020, 2932233, Page16 of 23
right to an impartial jury. See, e.g., United States v. Nelson, 277 F.3d 164, 201-04,
213 (2d Cir. 2002) (vacating conviction where distri
Case 20-3061, Document 38, 09/16/2020, 2932233, Page9 of 23
States v. Robinson, 473 F.3d 487, 490 (2d Cir. 2007). In over 70 years since
Cohen was decided, despite “numerous opportunities” to expand
Case 20-3061, Document 38, 09/16/2020, 2932233, Page6 of 23
use in prosecuting its criminal case, she would have a full opportunity to do so in
her pretrial motions in the criminal case before Judge
Case 20-3061, Document 38, 09/16/2020, 2932233, Page7 of 23
the Order. (Dist. Ct. Docket Entry 55). On September 10, 2020, Maxwell filed the
instant motion to consolidate this appeal with the appeal
Case 20-3061, Document 38, 09/16/2020, 2932233, Page1 of 23
UNITED STATES COURT OF APPEALS
FOR THE SECOND CIRCUIT
UNITED STATES OF AMERICA : AFFIRMATION
Appellee, : Dkt. No. 20-3061
_v.-
GHISLAIN
Case 20-3061, Document 37, 09/16/2020, 2932231, Page22 of 24
any legal objections to the Government’s evidence before Judge Nathan, who is
presiding over the criminal case. If Maxwell is dissatisfied
Case 20-3061, Document 37, 09/16/2020, 2932231, Page24 of 24
CERTIFICATE OF COMPLIANCE
Pursuant to Federal Rule of Appellate Procedure 32(g), the undersigned counsel
hereby certifies that this motio
Case 20-3061, Document 37, 09/16/2020, 2932231, Page21 of 24
these reasons alone, the Court should deny Maxwell’s motion to consolidate these
appeals.
27. Maxwell has filed two separate appeals chal
Case 20-3061, Document 37, 09/16/2020, 2932231, Page23 of 24
for this Court to adjudicate regarding Judge Nathan’s Order — the lone Order on
appeal in this matter — if the Court were to grant Maxwell
Case 20-3061, Document 37, 09/16/2020, 2932231, Page20 of 24
was founded on the principle that when intervenors seek access to sealed records,
“orders denying access are final as to the intervenors.”