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Document Case 22-1426, Document 1-2

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Case 22-1426, Document 1-2, 07/08/2022, 3344417, Page62 of 91 for the Southern District of New York, Thurgood Marshall U.S. Courthouse at 40 Foley Square, New York, New York. In accordance with its prior Order, the Court will ensure access for alleged victims and any members of the Defendants family. Dkt. No. 344. In order to comply with the Districts COVID-19 protocols, a number of pool reporters will be permitted in the courtroom proper as managed by the District Executives Office. Press will also be able to access the proceeding in dedicated overflow press rooms. The public will be able to access the proceeding in overflow Courtrooms 110 and 906 of the Thurgood Marshall U.S. Courthouse. These overflow rooms will have live video and audio feeds of the proceeding. The use of any electronic devices during the proceeding in the overflow rooms is strictly prohibited. (Signed by Judge Alison J. Nathan on 11/15/2021) (See ORDER set forth) (ap) (Entered: 11/15/2021) 11/15/2021 464 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C. Sternheim dated 11/15/2021 re: Late Receipt of Govt Disclosures to MDC (Sternheim, Bobbi) (Entered: 11/15/2021) 11/15/2021 465 TRANSCRIPT of Proceedings as to Ghislaine Maxwell re: Conference held on 11/1/21 before Judge Alison J. Nathan. Court Reporter/Transcriber: Michael McDaniel, (212) 805-0300, Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 12/6/2021. Redacted Transcript Deadline set for 12/16/2021. Release of Transcript Restriction set for 2/14/2022. (Moya, Goretti) (Entered: 11/15/2021) 11/15/2021 466 NOTICE OF FILING OF OFFICIAL TRANSCRIPT as to Ghislaine Maxwell. Notice is hereby given that an official transcript of a Conference proceeding held on 11/1/21 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days.... (Moya, Goretti) (Entered: 11/15/2021) 11/15/2021 467 TRANSCRIPT of Proceedings as to Ghislaine Maxwell re: Conference held on 11/10/21 before Judge Alison J. Nathan. Court Reporter/Transcriber: Sonya Ketter Moore, (212) 805-0300, Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 12/6/2021. Redacted Transcript Deadline set for 12/16/2021. Release of Transcript Restriction set for 2/14/2022. (Moya, Goretti) (Entered: 11/15/2021) 11/15/2021 468 NOTICE OF FILING OF OFFICIAL TRANSCRIPT as to Ghislaine Maxwell. Notice is hereby given that an official transcript of a Conference proceeding held on 11/10/21 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days.... (Moya, Goretti) (Entered: 11/15/2021) 11/15/2021 469 MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 464 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C. Sternheim dated 11/15/2021 re: Late Receipt of Govt Disclosures to MDC. ENDORSEMENT: It appears that the mail referenced in this letter was sent prior to the Court's memo endorsement of the Government's November 8, 2021 letter. Dkt. Nos. 422, 425. In any event, as this matter is less than two weeks before trial, the Government is ordered to send materials via FedEx and provide the tracking number to defense counsel. (Signed by Judge Alison J. Nathan on 11/15/2021) (ap) (Entered: 11/16/2021) 11/15/2021 Minute Entry for proceedings held before Judge Alison J. Nathan:Pretrial Conference as to Ghislaine Maxwell held on 11/15/2021. Defendant Ghislaine Maxwell. Defense counsel present with attorney Bobbi Sternheim, Jeff Pagliuca, Christian Everdell and Laura Menninger. AUSA Lara Pomerantz, Maurene Comey, Alison Moe and Andrew Rohrbach for the government. Court Reporter Rebecca Forman. See Transcript. (jw) (Entered: 12/09/2021) DOJ-OGR-00020448 --- PAGE BREAK --- Case 22-1426, Document 1-2, 07/08/2022, 3344417, Page80 of 91 exhibits and the sealing of Court Exhibit 4. The Court concludes that the proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006), and narrowly tailored. The redactions serve the purpose of protecting the anonymity of jurors and of victim-witnesses subject to the Court's anonymity order. With respect to Court Exhibit 4, rather than seal the entire document, the Court has redacted the information that would potentially identify the victim-witness who testified pursuant to the Court's anonymity order. Unredacted copies of the Court Exhibits will be filed under seal. (Signed by Judge Alison J. Nathan on 2/4/2022)(ap) (Entered: 02/04/2022) 02/04/2022 594 LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated February 4, 2022 re: Opposition to Defendant's Sealing Request Document filed by USA. (Pomerantz, Lara) (Entered: 02/04/2022) 02/08/2022 595 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C. Sternheim dated 2/8/2022 re: Request for Sealing (Sternheim, Bobbi) (Entered: 02/08/2022) 02/11/2022 596 ORDER as to Ghislaine Maxwell. The Court is in receipt of the parties' letters addressing the Defendant's request to temporarily seal her motion for a new trial and accompanying exhibits, and the Governments response in opposition and accompanying exhibits. See Dkt. Nos. 590, 594, 595. Several media organizations have also filed letters seeking unsealing. The Court is also in receipt of Juror 50's motion to intervene. Both the Government and the Defendant oppose intervention. The Defendant seeks to strike or, in the alternative, seal Juror 50's motion. For the reasons outlined more fully below, the Court rules as follows. First, the Defendant's motion to temporarily seal in their entirety all documents related to the motion for a new trial is DENIED. Any sealing of judicial documents must be narrowly tailored to serve competing interests. (Signed by Judge Alison J. Nathan on 2/11/22)(jw) (Entered: 02/11/2022) 02/11/2022 597 ORDER as to Ghislaine Maxwell. The Court's chambers received the attached letter via email from counsel for the National Association of Criminal Defense Lawyers (NACDL) seeking leave to file an amicus brief regarding the Defendant's motion for a new trial. The Court issues this Order in response. If any party wishes to file an amicus brief concerning the Defendant's motion for a new trial, it may submit to the Court via email a motion for leave to do so on or before February 18, 2022. The Court will only consider such a motion if: It is timely submitted by February 18, 2022; (Amicus Brief due by 2/18/2022) (Signed by Judge Alison J. Nathan on 2/11/22)(jw) (Entered: 02/11/2022) 02/11/2022 598 LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from Alison Moe, Maurene Comey, Lara Pomerantz, and Andrew Rohrbach dated February 11, 2022 re: motion by the New York Times Company. Document filed by USA. (Moe, Alison) (Entered: 02/11/2022) 02/11/2022 599 MOTION for New Trial to Obtain Relief Requested in Memorandum in Support of Post-Trial Motions. Document filed by Ghislaine Maxwell. (Everdell, Christian) (Entered: 02/11/2022) 02/11/2022 600 MEMORANDUM in Support by Ghislaine Maxwell re 599 MOTION for New Trial to Obtain Relief Requested in Memorandum in Support of Post-Trial Motions.. OMNIBUS MEMORANDUM in Support by Ghislaine Maxwell re Post-Trial Motions (Everdell, Christian) (Entered: 02/12/2022) 02/15/2022 601 SEALED DOCUMENT placed in vault. (jus) (Entered: 02/15/2022) 02/16/2022 602 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C. Sternheim dated 02/16/2022 re: Letter in Response to Dkt. 596 (Sternheim, Bobbi) (Entered: 02/16/2022) 02/16/2022 603 LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from Alison Moe, Maurene Comey, Lara Pomerantz, and Andrew Rohrbach dated February 16, 2022 re: Letter regarding proposed redactions. Document filed by USA. (Moe, Alison) (Entered: 02/16/2022) DOJ-OGR-00020466

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Page 62 of 91 - DOJ-OGR-00020448
Case 22-1426, Document 1-2, 07/08/2022, 3344417, Page62 of 91 for the Southern District of New York, Thurgood Marshall U.S. Courthouse at 40 Foley Square, New York, New York. In accordance with its prior Order, the Court will ensure access for alleged victims and any members of the Defendants family. Dkt. No. 344. In order to comply with the Districts COVID-19 protocols, a number of pool reporters will be permitted in the courtroom proper as managed by the District Executives Office. Press will also be able to access the proceeding in dedicated overflow press rooms. The public will be able to access the proceeding in overflow Courtrooms 110 and 906 of the Thurgood Marshall U.S. Courthouse. These overflow rooms will have live video and audio feeds of the proceeding. The use of any electronic devices during the proceeding in the overflow rooms is strictly prohibited. (Signed by Judge Alison J. Nathan on 11/15/2021) (See ORDER set forth) (ap) (Entered: 11/15/2021) 11/15/2021 464 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C. Sternheim dated 11/15/2021 re: Late Receipt of Govt Disclosures to MDC (Sternheim, Bobbi) (Entered: 11/15/2021) 11/15/2021 465 TRANSCRIPT of Proceedings as to Ghislaine Maxwell re: Conference held on 11/1/21 before Judge Alison J. Nathan. Court Reporter/Transcriber: Michael McDaniel, (212) 805-0300, Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 12/6/2021. Redacted Transcript Deadline set for 12/16/2021. Release of Transcript Restriction set for 2/14/2022. (Moya, Goretti) (Entered: 11/15/2021) 11/15/2021 466 NOTICE OF FILING OF OFFICIAL TRANSCRIPT as to Ghislaine Maxwell. Notice is hereby given that an official transcript of a Conference proceeding held on 11/1/21 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days.... (Moya, Goretti) (Entered: 11/15/2021) 11/15/2021 467 TRANSCRIPT of Proceedings as to Ghislaine Maxwell re: Conference held on 11/10/21 before Judge Alison J. Nathan. Court Reporter/Transcriber: Sonya Ketter Moore, (212) 805-0300, Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 12/6/2021. Redacted Transcript Deadline set for 12/16/2021. Release of Transcript Restriction set for 2/14/2022. (Moya, Goretti) (Entered: 11/15/2021) 11/15/2021 468 NOTICE OF FILING OF OFFICIAL TRANSCRIPT as to Ghislaine Maxwell. Notice is hereby given that an official transcript of a Conference proceeding held on 11/10/21 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days.... (Moya, Goretti) (Entered: 11/15/2021) 11/15/2021 469 MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 464 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C. Sternheim dated 11/15/2021 re: Late Receipt of Govt Disclosures to MDC. ENDORSEMENT: It appears that the mail referenced in this letter was sent prior to the Court's memo endorsement of the Government's November 8, 2021 letter. Dkt. Nos. 422, 425. In any event, as this matter is less than two weeks before trial, the Government is ordered to send materials via FedEx and provide the tracking number to defense counsel. (Signed by Judge Alison J. Nathan on 11/15/2021) (ap) (Entered: 11/16/2021) 11/15/2021 Minute Entry for proceedings held before Judge Alison J. Nathan:Pretrial Conference as to Ghislaine Maxwell held on 11/15/2021. Defendant Ghislaine Maxwell. Defense counsel present with attorney Bobbi Sternheim, Jeff Pagliuca, Christian Everdell and Laura Menninger. AUSA Lara Pomerantz, Maurene Comey, Alison Moe and Andrew Rohrbach for the government. Court Reporter Rebecca Forman. See Transcript. (jw) (Entered: 12/09/2021) DOJ-OGR-00020448
Page 80 of 91 - DOJ-OGR-00020466
Case 22-1426, Document 1-2, 07/08/2022, 3344417, Page80 of 91 exhibits and the sealing of Court Exhibit 4. The Court concludes that the proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006), and narrowly tailored. The redactions serve the purpose of protecting the anonymity of jurors and of victim-witnesses subject to the Court's anonymity order. With respect to Court Exhibit 4, rather than seal the entire document, the Court has redacted the information that would potentially identify the victim-witness who testified pursuant to the Court's anonymity order. Unredacted copies of the Court Exhibits will be filed under seal. (Signed by Judge Alison J. Nathan on 2/4/2022)(ap) (Entered: 02/04/2022) 02/04/2022 594 LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated February 4, 2022 re: Opposition to Defendant's Sealing Request Document filed by USA. (Pomerantz, Lara) (Entered: 02/04/2022) 02/08/2022 595 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C. Sternheim dated 2/8/2022 re: Request for Sealing (Sternheim, Bobbi) (Entered: 02/08/2022) 02/11/2022 596 ORDER as to Ghislaine Maxwell. The Court is in receipt of the parties' letters addressing the Defendant's request to temporarily seal her motion for a new trial and accompanying exhibits, and the Governments response in opposition and accompanying exhibits. See Dkt. Nos. 590, 594, 595. Several media organizations have also filed letters seeking unsealing. The Court is also in receipt of Juror 50's motion to intervene. Both the Government and the Defendant oppose intervention. The Defendant seeks to strike or, in the alternative, seal Juror 50's motion. For the reasons outlined more fully below, the Court rules as follows. First, the Defendant's motion to temporarily seal in their entirety all documents related to the motion for a new trial is DENIED. Any sealing of judicial documents must be narrowly tailored to serve competing interests. (Signed by Judge Alison J. Nathan on 2/11/22)(jw) (Entered: 02/11/2022) 02/11/2022 597 ORDER as to Ghislaine Maxwell. The Court's chambers received the attached letter via email from counsel for the National Association of Criminal Defense Lawyers (NACDL) seeking leave to file an amicus brief regarding the Defendant's motion for a new trial. The Court issues this Order in response. If any party wishes to file an amicus brief concerning the Defendant's motion for a new trial, it may submit to the Court via email a motion for leave to do so on or before February 18, 2022. The Court will only consider such a motion if: It is timely submitted by February 18, 2022; (Amicus Brief due by 2/18/2022) (Signed by Judge Alison J. Nathan on 2/11/22)(jw) (Entered: 02/11/2022) 02/11/2022 598 LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from Alison Moe, Maurene Comey, Lara Pomerantz, and Andrew Rohrbach dated February 11, 2022 re: motion by the New York Times Company. Document filed by USA. (Moe, Alison) (Entered: 02/11/2022) 02/11/2022 599 MOTION for New Trial to Obtain Relief Requested in Memorandum in Support of Post-Trial Motions. Document filed by Ghislaine Maxwell. (Everdell, Christian) (Entered: 02/11/2022) 02/11/2022 600 MEMORANDUM in Support by Ghislaine Maxwell re 599 MOTION for New Trial to Obtain Relief Requested in Memorandum in Support of Post-Trial Motions.. OMNIBUS MEMORANDUM in Support by Ghislaine Maxwell re Post-Trial Motions (Everdell, Christian) (Entered: 02/12/2022) 02/15/2022 601 SEALED DOCUMENT placed in vault. (jus) (Entered: 02/15/2022) 02/16/2022 602 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C. Sternheim dated 02/16/2022 re: Letter in Response to Dkt. 596 (Sternheim, Bobbi) (Entered: 02/16/2022) 02/16/2022 603 LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from Alison Moe, Maurene Comey, Lara Pomerantz, and Andrew Rohrbach dated February 16, 2022 re: Letter regarding proposed redactions. Document filed by USA. (Moe, Alison) (Entered: 02/16/2022) DOJ-OGR-00020466