Document 48

Case 1:19-cr-00490-RMB Document 48 Filed 08/21/19 Page 1 of 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, -against- JEFFREY EPSTEIN, Defendant. The Court will conduct a brief hearing on Tuesday, August 27, 2019 at 10:30 a.m. in connection with the nolle prosequi order proposed to the Court on August 19, 2019 by the United States Attorney. The Court believes that where, as here, a defendant has died before any judgment has been entered against him, the public may still have an informational interest in the process by which the prosecutor seeks dismissal of an indictment. At the hearing, Counsel for the Government and for the deceased Defendant, Jeffrey Epstein, will be heard. Counsel for the victims and the victims will also be heard, if they wish to be. The hearing will be held in Courtroom 17B. Dated: New York, New York August 21, 2019 RMB RICHARD M. BERMAN, U.S.D.J. DOJ-OGR-00000630 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 48 Filed 08/24/20 Page 1 of 2 Haddon, Morgan and Foreman, P.C Laura A. Menninger 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com lmenninger@hmflaw.com August 24, 2020 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, New York 10007 Re: Request to File Under Seal: Proposed Redactions to Request to Modify Protective Order and Reply in Support Thereof United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: This is a letter motion to file under seal Ms. Maxwell's Proposed Redactions to Request to Modify Protective Order ("Proposed Redactions") as well as her Reply in Support of Request to Modify Protective Order ("Reply"). The Protective Order in this case states: The Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses, and Other Authorized Persons are prohibited from filing publicly as an attachment to a filing or excerpted within a filing any Confidential Information or Highly Confidential Information referenced in the Discovery, unless authorized by the Government in writing or by Order of the Court. Any such filings must be filed under seal, unless authorized by the Government in writing or by Order of the Court. See Protective Order (Doc. 36) at ¶ 15. The Proposed Redactions and the Reply contain content designated as Confidential Information by the Government under the terms of the Protective Order. Ms. Maxwell therefore requests permission to file the Proposed Redactions and Reply under seal, at least until such time as the Court has ruled on the proposed redactions set forth therein. DOJ-OGR-00001741 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 48 Filed 08/24/20 Page 2 of 2 Hon. Alison J. Nathan August 24, 2020 Page 2 Sincerely, HADDON, MORGAN AND FOREMAN, P.C. /s/ Laura A. Menninger Laura A. Menninger CC: All Counsel of Record (Via ECF) DOJ-OGR-00001742