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Document 48

AI Analysis

Summary: The document is a letter motion filed by Laura A. Menninger, attorney for Ghislaine Maxwell, requesting permission to file under seal certain documents related to a request to modify a Protective Order in the case United States v. Ghislaine Maxwell. The request is based on the Protective Order's requirement to file Confidential Information under seal. The document includes references to a related case involving Jeffrey Epstein.
Significance: This document is significant because it reveals the defense's request to file certain documents under seal in the Ghislaine Maxwell case, citing a Protective Order and the inclusion of Confidential Information designated by the Government.
Key Topics: Request to File Under Seal Protective Order Ghislaine Maxwell Case
Key People:
  • Laura A. Menninger - Defense Attorney for Ghislaine Maxwell
  • Ghislaine Maxwell - Defendant
  • Alison J. Nathan - United States District Judge
  • Jeffrey Epstein - Deceased Defendant in related case
  • Richard M. Berman - United States District Judge in Jeffrey Epstein's case
Document Type
Court Filing
Date
08/21/19
Pages
5
Folder
IMAGES001, IMAGES008, IMAGES009
Has Handwriting
Yes
Has Stamps
Yes

Full Text

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 1:19-cr-00830-AT Document 48 Filed 03/10/21 Page 1 of 1 The Law Offices of MONTELL FIGGINS,LLC 17 Academy Street, Suite 305 Newark, New Jersey 07102 Phone: (973) 242-4700 Fax: (973) 242-4701 www.figginslaw.com BRANCH OFFICES: 140 East Ridgewood Avenue Paramus, NJ 07640 Reply to Newark Office [X] 30 Wall Street 8th Floor New York, NY 1005 Of Counsel Douglas Mitchell, Esq. Linda Childs, Esq. March 10, 2021 SENT VIA ECF Honorable Analisa Torres U.S. Southern District of NY 500 Pearl Street New York, NY 10007 Re: USA v Michael Thomas, et al. Docket No.: 1:19-cr-00830 Request for Emergency Out of State Travel Your Honor, This firm represents Defendant, Michael Thomas, in the above-captioned matter. We are seeking the courts permission for Michael Thomas to take an emergency trip to the State of Georgia to tend to his sick father. Kristen McKeown, his pre-trial services officer, does not oppose his emergency travel. Respectfully yours /s/ Montell Figgins Montell Figgins, Esq. Attorney for Defendant Michael Thomas cc: Nicolas Roos, Esq., Counsel for Plaintiff Rebekah Donaleski, Esq., Counsel for Plaintiff Jessica Lonergan, Esq., Counsel for Plaintiff Jason Erroy Foy, Esq, Counsel for Defendant Noel DOJ-OGR-00022117 --- PAGE BREAK --- 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. ORDER 19 Cr 490 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-00023818 --- 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

Individual Pages

Page 1 - DOJ-OGR-00000630
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 1 - DOJ-OGR-00001741
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 1 - DOJ-OGR-00022117
Case 1:19-cr-00830-AT Document 48 Filed 03/10/21 Page 1 of 1 The Law Offices of MONTELL FIGGINS,LLC 17 Academy Street, Suite 305 Newark, New Jersey 07102 Phone: (973) 242-4700 Fax: (973) 242-4701 www.figginslaw.com BRANCH OFFICES: 140 East Ridgewood Avenue Paramus, NJ 07640 Reply to Newark Office [X] 30 Wall Street 8th Floor New York, NY 1005 Of Counsel Douglas Mitchell, Esq. Linda Childs, Esq. March 10, 2021 SENT VIA ECF Honorable Analisa Torres U.S. Southern District of NY 500 Pearl Street New York, NY 10007 Re: USA v Michael Thomas, et al. Docket No.: 1:19-cr-00830 Request for Emergency Out of State Travel Your Honor, This firm represents Defendant, Michael Thomas, in the above-captioned matter. We are seeking the courts permission for Michael Thomas to take an emergency trip to the State of Georgia to tend to his sick father. Kristen McKeown, his pre-trial services officer, does not oppose his emergency travel. Respectfully yours /s/ Montell Figgins Montell Figgins, Esq. Attorney for Defendant Michael Thomas cc: Nicolas Roos, Esq., Counsel for Plaintiff Rebekah Donaleski, Esq., Counsel for Plaintiff Jessica Lonergan, Esq., Counsel for Plaintiff Jason Erroy Foy, Esq, Counsel for Defendant Noel DOJ-OGR-00022117
Page 1 - DOJ-OGR-00023818
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. ORDER 19 Cr 490 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-00023818
Page 2 - DOJ-OGR-00001742
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