Relationship Details

This document is page 13 of a legal filing (Case 20-3061) dated October 8, 2020, concerning Ghislaine Maxwell. It argues that releasing deposition material prematurely would compromise her ability to make a 'Martindell argument' and discusses her intent to move Judge Preska to stay unsealing pending her criminal case. The text highlights a conflict where Maxwell claims she cannot fairly argue her case because Judge Preska and the appellate panel are unaware of redacted facts regarding government proceedings and subpoenas.

This document is a page from a legal filing dated September 10, 2020, discussing the unsealing of deposition materials in the Ghislaine Maxwell case. It details procedural history where Maxwell requested a stay on unsealing due to 'critical new information' she could not disclose because of a criminal protective order overseen by Judge Nathan. Judge Preska declined the stay but remained open to reevaluation if Judge Nathan modified the protective order.

This document is page 29 (labeled Page 34 of 58 in the header) of a legal brief filed on September 24, 2020, on behalf of Ghislaine Maxwell. It argues that the government is acting inconsistently by intervening to stay proceedings in the civil case 'Doe v. Indyke' to protect the criminal prosecution's integrity, while failing to do the same in 'Giuffre v. Maxwell' regarding unsealing deposition materials. The text highlights that Jane Doe alleges abuse by both Epstein and Maxwell when she was a minor.

This page from a legal brief (Case 20-3061) dated October 8, 2020, argues that the appellate court has jurisdiction to review Judge Preska's decision because Judge Nathan's order is unreviewable post-judgment. The text counters the Government's arguments regarding the unsealing of confidential criminal discovery materials and references a previous motion to consolidate cases. Significant portions of the text are redacted.

This document is page 32 of a legal filing (dated Sept 24, 2020) arguing against the unsealing of deposition material. The text contends that unsealing the material would prevent Judge Preska from reconsidering her decision based on new information about how the government obtained the material, and would prejudice Ms. Maxwell's ability to argue before Judge Nathan that perjury counts should be dismissed due to the government's circumvention of the 'Martindell' precedent.

This document is page 19 of a legal filing (Case 20-3061) dated October 8, 2020, likely an appellate brief filed by Ms. Maxwell's defense. It argues that Judge Preska (civil case) is evaluating unsealing documents without knowing critical facts obscured by a criminal protective order overseen by Judge Nathan. The defense contends that unless the order is modified to allow sharing information under seal, Maxwell's right to a fair trial by an impartial jury will be prejudiced by the release of deposition materials.

This document is page 6 of a legal filing dated September 28, 2020, concerning Case 20-3061. It presents a legal argument distinguishing the current appeal from *Flanagan v. United States*, asserting that Ghislaine Maxwell's appeal regarding Judge Nathan's order is comparable to a bail reduction motion because the harm (unsealing deposition materials) would be irreversible ("the cat is irretrievably out of the bag") if not addressed immediately. The text argues that Maxwell must be allowed to share information from Judge Nathan with Judge Preska to prevent the unsealing order from going into effect without reconsideration.

This document is page 14 of a legal filing from September 24, 2020, concerning Ghislaine Maxwell's appeals. It outlines the procedural posture of two related appeals: one regarding Judge Preska's order unsealing deposition materials in the civil case (Giuffre v. Maxwell), and the current appeal regarding Judge Nathan's denial of a motion to modify a criminal protective order. Maxwell has moved to consolidate these two appeals.