Case 21-58, Document 1-1, 01/12/2021, 3011673, Page1 of 2

# United States Court of Appeals for the Second Circuit Thurgood Marshall U.S. Courthouse 40 Foley Square New York, NY 10007

DEBRA ANN LIVINGSTON
CHIEF JUDGE

CATHERINE O'HAGAN WOLFE
CLERK OF COURT

Date: January 12, 2021 Docket #: 21-58 Short Title: United States of America v. Maxwell

DC Docket #: 1:20-cr-330-1
DC Court: SDNY (NEW YORK
CITY)
DC Judge: Nathan

# DOCKETING NOTICE

An appeal in the above-referenced case has been docketed under number: 21-58. This number must appear on all documents related to this case that are filed in this Court. Appellate counsel of record either represented the appellant before the district court, filed the notice of appeal, or acted as counsel for appellee in the district court. For pro se parties the docket sheet with the caption page, and an Acknowledgment and Notice of Appearance Form are enclosed. In counseled cases the docket sheet is available on PACER. Counsel must access the Acknowledgment and Notice of Appearance Form from this Court's website http://www.ca2.uscourts.gov.

# DOCKETING NOTICE (cont.)

The form must be completed and returned within 14 days of the date of this notice. The form requires the following information:

YOUR CORRECT CONTACT INFORMATION: Review the party information on the docket sheet and note any incorrect information in writing on the Acknowledgment and Notice of Appearance Form.

The Court will contact one counsel per party or group of collectively represented parties when serving notice or issuing our order. Counsel must designate on the Acknowledgment and Notice of Appearance a lead attorney to accept all notices from this Court who, in turn will, be responsible for notifying any associated counsel.

CHANGE IN CONTACT INFORMATION: An attorney or pro se party who does not immediately notify the Court when contact information changes will not receive notices, documents and orders filed in the case.

# Case 21-58, Document 1-1, 01/12/2021, 3011673, Page2 of 2

# Case 21-58, Document 1-1, 01/12/2021, 3011673, Page2 of 2 (cont.)

An attorney and any pro se party who is permitted to file documents electronically in CM/ECF must notify the Court of a change to the user's mailing address, business address, telephone number, or e-mail. To update contact information, a Filing User must access PACER's Manage My Appellate Filer Account, https://www.pacer.gov/psco/cgi-bin/cmecf/ea-login.pl. The Court's records will be updated within 1 business day of a user entering the change in PACER.

A pro se party who is not permitted to file documents electronically must notify the Court of a change in mailing address or telephone number by filing a letter with the Clerk of Court.

CAPTION: In an appeal, the Court uses the district court caption pursuant to FRAP 12(a), 32(a). For a petition for review or original proceeding the Court uses a caption pursuant to FRAP 15(a) or 21(a), respectively. Please review the caption carefully and promptly advise this Court of any improper or inaccurate designations in writing on the Acknowledgment and Notice of Appearance form. If a party has been terminated from the case the caption may reflect that change only if the district court judge ordered that the caption be amended.

# Case 21-58, Document 1-1, 01/12/2021, 3011673, Page2 of 2 (cont.)

APPELLATE DESIGNATIONS: Please review whether petitioner is listed correctly on the party listing page of the docket sheet and in the caption. If there is an error, please note on the Acknowledgment and Notice of Appearance Form. Timely submission of the Acknowledgment and Notice of Appearance Form will constitute compliance with the requirement to file a Representation Statement required by FRAP 12(b).

For additional information consult the Court's instructions posted on the website.

Inquiries regarding this case may be directed to 212-857-8577.

Case 1s202dr-00330ЄAnDocumen21321File 0171/ 1

Criminal Notice of Appeal - Form A

DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED:January 11, 2021

# NOTICE OF APPEAL

United States District Court

Southern District of New York

Caption:
United States v.
Ghislaine Maxwell
Docket No.: 1:20-CR-00330
Alison J. Nathan
(District Court Judge)

Notice is hereby given that Ghislaine Maxwell appeals to the United States Court of
Appeals for the Second Circuit from the judgment , other [x] Order Denying Defendant's Renewed Motion for Release on Bail
entered in this action on 12/28/2020
(date)
(specify)

This appeal concerns: Conviction only [ ] Sentence only [ ] Conviction & Sentence [ ] Other [x]
Defendant found guilty by plea | trial | N/A |
Offense occurred after November 1, 1987? Yes [x] No [ ]
N/A [

Date of sentence: N/A [x]

Bail/Jail Disposition: Committed [x] Not committed | N/A |

Appellant is represented by counsel? Yes [x] No |
If yes, provide the following information:

Defendant's Counsel: Christian Everdell
Counsel's Address: Cohen & Gresser LLP
800 Third Avenue, New York, NY 10022
Counsel's Phone: 212-957-7600

Assistant U.S. Attorney: Maureen Corney
AUSA's Address: 1 St. Andrew's Plaza
New York, NY 10007
AUSA's Phone: 212-637-2200

Christian R. Everdell /S/SS
Signature

Case 21-58, Document 1-2, 01/12/2021, 3011673, Page2 of 19

ECF,INTAPP

# U.S. District Court Southern District of New York (Foley Square) CRIMINAL DOCKET FOR CASE #: 1:20-cr-00330-AJN AII Defendants

Case title: USA v. Maxwell

Date Filed: 06/29/2020

Assigned to: Judge Alison J.
Nathan

## Defendant (1)

Ghislaine Maxwell
also known as
Sealed Defendant 1

represented by Christian R. Everdell
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
212-707-7268
Fax: 212-957-4514
Email: ceverdell@cohengresser.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Jeffrey S. Pagliuca
Haddon Morgan and Foreman
150 East 10th Avenue
Denver, CO 80203
(303)-831-7364
Fax: (303)-832-2628
Email: ipagliuca@hmflaw.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Disposition

Laura A. Menninger
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
(303)-831-7364
Fax: (303)-832-2628
Email: lmenninger@hmflaw.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Mark Stewart Cohen
Cohen & Gresser, LLP (NYC)
800 Third Avenue
New York, NY 10022
(212) 957-7600
Fax: (212)957-4514
Email: mcohen@cohengresser.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Bobbi C Sternheim
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
(212) 243-1100
Fax: (888) 587-4737
Email: bc@sternheimlaw.com
ATTORNEY TO BE NOTICED

Pending Counts

# Case 21-58, Document 1-2, 01/12/2021, 3011673, Page3 of 19

18:371.F CONSPIRACY TO
ENTICE MINORS TO TRAVEL
TO ENGAGE IN ILLEGAL SEX
ACTS
(1)

18:371.F CONSPIRACY TO
ENTICE MINORS TO TRAVEL
TO ENGAGE IN ILLEGAL SEX
ACTS
(1s)

18:2422.F COERCION OR
ENTICEMENT OFA MINOT TO
TRAVEL TO ENGAGE IN
ILLEGAL SEX ACTS
(2)

18:2422.F COERCION OR
ENTICEMENT OF MINOR TO
ENGAGE IN ILLEGAL SEX
ACTS
(2s)

18:371.F CONSPIRACY TO
TRANSPORT MINORS WITH
INTENT TO ENGAGE IN
CRIMINAL SEXUAL ACTIVITY
(3)

18:371.F 18:371.F CONSPIRACY
TO TRANSPORT MINORS WITH
INTENT TO ENGAGE IN
CRIMINAL SEXUAL ACTIVITY
(3s)

18:2423.F COERCION OR
ENTICEMENT OF MINOR
FEMALE (TRANSPORTATION
OF A MINOR WITH INTENT TO
ENGAGE IN CRIMINAL
SEXUAL ACTIVITY)
(4)

18:2423.F TRANSPORTATION
OF A MINOR WITH INTENT TO
ENGAGE IN CRIMINAL
SEXUAL ACTIVITY
(4s)

18:1623.F FALSE
DECLARATIONS BEFORE
GRAND JURY/COURT
(PERJURY)
(5-6)

18:1623.F FALSE
DECLARATIONS BEFORE
GRAND JURY/COURT
(5s-6s)

Highest Offense Level (Opening)
Felony

## Terminated Counts

None

Disposition

# Case 21-58, Document 1-2, 01/12/2021, 3011673, Page4 of 19

Highest Offense Level
(Terminated)

None

# Case 21-58, Document 1-2, 01/12/2021, 3011673, Page4 of 19 (cont.)

<table><tr><th>Complaints</th><th>Disposition</th><th></th></tr><tr><td>None</td><td></td><td></td></tr><tr><td>Plaintiff</td><td></td><td></td></tr><tr><td>USA</td><td>represented by</td><td>Alex Rossmiller
U.S. Attorney's Office, Southern District of
New York
1 St. Andrew's Plaza
New York, NY 10007
(212) 637-2415
Email: alexander.rossmiller@usdoj.gov
LEAD ATTORNEY
PRO HAC VICE
ATTORNEY TO BE NOTICED
Designation: Assistant US Attorney</td></tr><tr><td></td><td></td><td>Alison Gainfort Moe
United States Attorney's Office, SDNY
One Saint Andrew's Plaza
New York, NY 10007
(212) 637-2225
Email: alison.moe@usdoj.gov
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Designation: Assistant US Attorney</td></tr><tr><td></td><td></td><td>Maurene Ryan Comey
United States Attorney's Office, SDNY
One Saint Andrew's Plaza
New York, NY 10007
(212) 637-2324
Email: maurene.comey@usdoj.gov
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Designation: Assistant US Attorney

Andrew Rohrbach
DOJ-USAO
1 St. Andrew's Plaza
New York, NY 10007
212-637-2345
Email: Andrew.Rohrbach@usdoj.gov
ATTORNEY TO BE NOTICED

Lara Elizabeth Pomerantz
United States Attorney's Office
One St. Andrew's Plaza
New York, NY 10007
212-637-2343
Fax: 212-637-2527
Email: Lara.Pomerantz@usdoj.gov
ATTORNEY TO BE NOTICED</td></tr></table>

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Date Filed

# Docket Text

# Case 21-58, Document 1-2, 01/12/2021, 3011673, Page5 of 19

<table><tr><th>06/29/2020</th><th>1</th><th>SEALED INDICTMENT as to Sealed Defendant 1 (1) count(s) 1, 2, 3, 4, 5-6. (jm)
(Main Document 1 replaced on 7/2/2020) (jm). (Entered: 07/02/2020)</th></tr><tr><td>07/02/2020</td><td>2</td><td>Order to Unseal Indictment as to Sealed Defendant 1. (Signed by Magistrate Judge
| Katharine H. Parker on 7/2/20)(jm) (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td></td><td>| INDICTMENT UNSEALED as to Ghislaine Maxwell. (jm) (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td></td><td>Case Designated ECF as to Ghislaine Maxwell. (jm) (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td></td><td>Case as to Ghislaine Maxwell ASSIGNED to Judge Alison J. Nathan. (jm) (Entered:
07/02/2020)</td></tr><tr><td>07/02/2020</td><td></td><td>Attorney update in case as to Ghislaine Maxwell. Attorney Alex Rossmiller, Maurene
Ryan Comey,Alison Gainfort Moe for USA added. (jm) (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td>4</td><td>MOTION to detain defendant. Document filed by USA as to Ghislaine Maxwell.
(Moe, Alison) (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td></td><td>Arrest of Ghislaine Maxwell in the United States District Court - District of New
Hampshire. (jm) (Entered: 07/06/2020)</td></tr><tr><td>07/05/2020</td><td>5</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Alex Rossmiller dated July 5, 2020 re:
Request to Schedule Initial Appearance Document filed by USA. (Comey, Maurene)
(Entered: 07/05/2020)</td></tr><tr><td>07/06/2020</td><td>6</td><td>Rule 5(c)(3) Documents Received as to Ghislaine Maxwell from the United States
District Court District of New Hampshire. (jm) (Entered: 07/06/2020)</td></tr><tr><td>07/06/2020</td><td>7</td><td>ORDER as to Ghislaine Maxwell. This matter has been assigned to me for all
purposes. In its July 5, 2020 letter, the Government on behalf of the parties requested
that the Court schedule an arraignment, initial appearance, and bail hearing in this
matter in the afternoon of Friday, July 10. See Dkt. No. 5. In light of the COVID
public health crisis, there are significant safety issues related to in-court proceedings.
If the Defendant is willing to waive her physical presence, this proceeding will be
conducted remotely. To that end, defense counsel should confer with the Defendant
regarding waiving her physical presence. If the Defendant wishes to waive her
physical presence for this proceeding, she and her counsel should sign the attached
form in advance of the proceeding if feasible. If this proceeding is to be conducted
remotely, there are protocols at the Metropolitan Detention Center that limit the times
at which the Defendant could be produced so that she could appear by video. In the
next week, the Defendant could be produced by video at either 9:00 a.m. on July 9,
2020 or sometime during the morning of July 14, 2020. Counsel are hereby ordered to
meet and confer regarding scheduling for this initial proceeding in light of these
constraints. If counsel does anticipate proceeding remotely, by 9:00 p.m. tonight,
counsel should file a joint letter proposing a date and time for the proceeding
consistent with this scheduling information, as well as a revised briefing schedule for
the Defendant's bail application.SO ORDERED. (Signed by Judge Alison J. Nathan on
7/6/2020)(jbo) (Entered: 07/06/2020)</td></tr><tr><td>07/06/2020</td><td>8</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Mark S.
Cohen dated July 6, 2020 re: Scheduling (Cohen, Mark) (Entered: 07/06/2020)</td></tr><tr><td>07/07/2020</td><td>2</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
Alex Rossmiller dated July 7, 2020 re: scheduling Document filed by USA.
(Rossmiller, Alex) (Entered: 07/07/2020)</td></tr><tr><td>07/07/2020</td><td>10</td><td>ORDER as to Ghislaine Maxwell. An arraignment, initial conference, and bail hearing
in this matter is hereby scheduled to occur as a remote video/teleconference using an
internet platform on July 14, 2020 at 1 p.m. In advance of the conference, Chambers
will email counsel with further information on how to access the video conference. To
optimize the quality of the video feed, only the Court, the Defendant, defense counsel,
and counsel for the Government will appear by video for the proceeding; all others
may access the audio of the public proceeding by telephone. Due to the limited
capacity of the internet platform system, only one attorney per party may participate
by video. Co-counsel, members of the press, and the public may access the audio feed
of the proceeding by calling a dial-in number, which the Court will provide in</td></tr></table>

# Case 21-58, Document 1-2, 01/12/2021, 3011673, Page6 of 19

<table><tr><th></th><th></th><th>advance of the proceeding by subsequent order. Given the high degree of public
interest in this case, a video feed of the remote proceeding will be available for
viewing in the Jury Assembly Room located at the Daniel Patrick Moynihan
Courthouse, 500 Pearl Street, New York, NY. Due to social distancing requirements,
| seating will be extremely limited; when capacity is reached no additional persons will
be admitted. Per the S.D.N.Y. COVID-19 Courthouse Entry Program, anyone who
appears at any S.D.N.Y. courthouse must complete a questionnaire on the date of the
proceeding prior to arriving at the courthouse. All visitors must also have their
temperature taken when they arrive at the courthouse. Please see the instructions,
attached. Completing the questionnaire ahead of time will save time and effort upon
entry. Only persons who meet the entry requirements established by the questionnaire
and whose temperatures are below 100.4 degrees will be allowed to enter the
courthouse. Face coverings that cover the nose and mouth must be worn at all times.
Anyone who fails to comply with the COVID-19 protocols that have been adopted by
the Court will be required to leave the courthouse. There are no exceptions. As
discussed in the Court's previous order, defense counsel shall, if possible, discuss the
Waiver of Right to be Present at Criminal Proceeding with the Defendant prior to the
proceeding. See Dkt. No. 7. If the Defendant consents, and is able to sign the form
(either personally or, in accordance with Standing Order 20-MC-174 of March 27,
2020, by defense counsel), defense counsel shall file the executed form at least 24
hours prior to the proceeding. In the event the Defendant consents, but counsel is
unable to obtain or affix the Defendant's signature on the form, the Court will conduct
an inquiry at the outset of the proceeding to determine whether it is appropriate for the
Court to add the Defendant's signature to the form. Pursuant to 18 U.S.C. § 3771(c)(1),
the Government must make their best efforts to see that crime victims are notified of,
and accorded, the rights provided to them in that section. This includes [t]he right to
reasonable, accurate, and timely notice of any public court proceeding... involving the
crime or of any release... of the accused and "[t]he right to be reasonably heard at any
public proceeding in the district court involving release." Id. § 3771(a)(2), (4). The
Court will inquire with the Government as to the extent of those efforts. So that
appropriate logistical arrangements can be made, the Government shall inform the
Court by email within 24 hours in advance of the proceeding if any alleged victim
wishes to be heard on the question of detention pending trial. Finally, the time between
the Defendant's arrest and July 6, 2020 is excluded under the Speedy Trial Act due to
the delay involved in transferring the Defendant from another district. See 18 U.S.C. §
3161(h)(1)(F). And the Court further excludes time under the Speedy Trial Act from
today through July 14, 2020. Due to the logistical issues involved in conducting a
remote proceeding, the Court finds "that the ends of justice served by [this exclusion]
outweigh the best interest of the public and the defendant in a speedy trial." 18 U.S.C.
§ 3161(h)(7)(A). The exclusion is also supported by the need for the parties to discuss
a potential protective order, which will facilitate the timely production of discovery in
a manner protective of the rights of third parties. See Dkt. No. 5. SO ORDERED.
(Signed by Judge Alison J. Nathan on 7/7/2020)(jbo) (Entered: 07/07/2020)</th></tr><tr><td>07/08/2020</td><td>11</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on 2 LETTER by USA as to
Ghislaine Maxwell addressed to Judge Alison J. Nathan from Alex Rossmiller dated
July 7, 2020 re: scheduling. ENDORSEMENT: The Court hereby sets the following
briefing schedule. The Defense response is due by 1:00 p.m. on July 10, 2020. The
Government reply is due by 1:00 p.m. on July 13, 2020. Additionally, defense counsel
is ordered to file notices of appearance on the docket by the end of the day today. SO
ORDERED. (Responses due by 7/10/2020. Replies due by 7/13/2020.) (Signed by
Judge Alison J. Nathan on 7/8/2020) (Inl) (Entered: 07/08/2020)</td></tr><tr><td>07/08/2020</td><td>12</td><td>NOTICE OF ATTORNEY APPEARANCE: Mark Stewart Cohen appearing for
| Ghislaine Maxwell. Appearance Type: Retained. (Cohen, Mark) (Entered: 07/08/2020)</td></tr><tr><td>07/08/2020</td><td>13</td><td>NOTICE OF ATTORNEY APPEARANCE: Christian R. Everdell appearing for
Ghislaine Maxwell. Appearance Type: Retained. (Everdell, Christian) (Entered:
07/08/2020)</td></tr><tr><td>07/08/2020</td><td>14</td><td>NOTICE OF ATTORNEY APPEARANCE: Laura A. Menninger appearing for
Ghislaine Maxwell. Appearance Type: Retained. (Menninger, Laura) (Entered:
07/08/2020)</td></tr></table>

# Case 21-58, Document 1-2, 01/12/2021, 3011673, Page7 of 19

<table><tr><th>07/08/2020</th><th>15</th><th>MOTION for Jeffrey S. Pagliuca to Appear Pro Hac Vice. Filing fee $ 200.00, receipt
number ANYSDC-20605229. Motion and supporting papers to be reviewed by
Clerk's Office staff. Document filed by Ghislaine Maxwell. (Attachments: # 1 Exhibit
Declaration of Jeffrey S. Pagliuca, # 2 Exhibit Certificate of Good Standing, # 3 Text
of Proposed Order Proposed Order)(Pagliuca, Jeffrey) (Entered: 07/08/2020)</th></tr><tr><td>07/08/2020</td><td>17</td><td>(S1) SUPERSEDING INDICTMENT FILED as to Ghislaine Maxwell (1) count(s) 1s,
2s, 3s, 4s, 5s-6s. (jm) (Entered: 07/10/2020)</td></tr><tr><td>07/09/2020</td><td></td><td>&gt;&gt;&gt;NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document
No. 15 MOTION for Jeffrey S. Pagliuca to Appear Pro Hac Vice. Filing fee $
200.00, receipt number ANYSDC-20605229. Motion and supporting papers to be
reviewed by Clerk's Office staff. The document has been reviewed and there are
no deficiencies. (aea) (Entered: 07/09/2020)</td></tr><tr><td>07/09/2020</td><td>16</td><td>ORDER as to Ghislaine Maxwell. As discussed in its previous order, the Court will
hold an arraignment, initial conference, and bail hearing in this matter remotely as a
video/teleconference on July 14, 2020 at 1 pm. Members of the press and the public in
the United States may access the live audio feed of the proceeding by calling
855-268-7844 and using access code 32091812# and PIN 9921299#. Those outside of
the United States may access the live audio feed by calling 214-416-0400 and using
the same access code and PIN. These phone lines can accommodate approximately
500 callers on a first come, first serve basis. The Court will provide counsel for both
sides an additional dial-in number to be used to ensure audio access to the proceeding
for non-speaking co-counsel, alleged victims, and any family members of the
Defendant. The United States Attorney's Office should email Chambers with
information regarding any alleged victims who are entitled, pursuant to 18 U.S.C.
$3771(a)(4), to be heard at the bail hearing and who wish to be heard. The Court will
then provide information as to the logistics for their dial-in access. As the Court
described in a previous order, members of the press and public may watch and listen to
the live video feed in the Jury Assembly Room, at the Daniel Patrick Moynihan
Courthouse, 500 Pearl Street. See Dkt. No. 10. However, in light of COVID-19,
seating will be limited to approximately 60 seats in order to enable appropriate social
| distancing and ensure public safety. Counsel for the Defendant and the Government
| may contact Chambers by email if there is a request to accommodate alleged victims
| or family members of the Defendant. Members of the credentialed in-house press
corps may contact the District Executive's Office about seating. Otherwise, all seating
will be allocated on a first come, first serve basis and in accordance with the S.D.N.Y.
|COVID-19 Courthouse Entry Program and this Court's previous order of July 7, 2020.
See Dkt. No. 10. If conditions change or the Court otherwise concludes that allowing
for in-person viewing of the video feed at the courthouse is not consistent with public
health, the Court may provide audio access by telephone only. Any photographing,
recording, or rebroadcasting of federal court proceedings is prohibited by law.
Violation of these prohibitions may result in fines or sanctions, including removal of
| court issued media credentials, restricted entry to future hearings, denial of entry to
future hearings, or any other sanctions deemed necessary by the Court. SO
ORDERED. (Signed by Judge Alison J. Nathan on 7/9/2020)(jbo) (Entered:
07/09/2020)</td></tr><tr><td>07/10/2020</td><td>18</td><td>MEMORANDUM in Opposition by Ghislaine Maxwell re 4 MOTION to detain
defendant.. (Cohen, Mark) (Entered: 07/10/2020)</td></tr><tr><td>07/10/2020</td><td>19</td><td>NOTICE OF ATTORNEY APPEARANCE: Mark Stewart Cohen appearing for
Ghislaine Maxwell. Appearance Type: Retained. (Cohen, Mark) (Entered: 07/10/2020)</td></tr><tr><td>07/10/2020</td><td>20</td><td>NOTICE OF ATTORNEY APPEARANCE: Christian R. Everdell appearing for
Ghislaine Maxwell. Appearance Type: Retained. (Everdell, Christian) (Entered:
07/10/2020)</td></tr><tr><td>07/10/2020</td><td>21</td><td>WAIVER of Personal Appearance at Arraignment and Entry of Plea of Not Guilty by
Ghislaine Maxwell. (Everdell, Christian) (Entered: 07/10/2020)</td></tr><tr><td>07/13/2020</td><td>22</td><td>REPLY MEMORANDUM OF LAW in Support by USA as to Ghislaine Maxwell re:
4 MOTION to detain defendant. . (Moe, Alison) (Entered: 07/13/2020)</td></tr><tr><td>07/13/2020</td><td></td><td>ORDER granting 15 Motion for Jeffrey Pagliuca to Appear Pro Hac Vice as to
Ghislaine Maxwell (1). (Signed by Judge Alison J. Nathan on 7/13/2020) (kwi)</td></tr></table>

# Case 21-58, Document 1-2, 01/12/2021, 3011673, Page8 of 19

<table><tr><th></th><th></th><th>(Entered: 07/13/2020)</th></tr><tr><td>07/14/2020</td><td>23</td><td>ORDER as to Ghislaine Maxwell. For the reasons stated on the record at today's
proceeding, the Governments motion to detain the Defendant pending trial is hereby
GRANTED (Signed by Judge Alison J. Nathan on 7/14/20)(jw) (Entered: 07/14/2020)</td></tr><tr><td>07/14/2020</td><td></td><td>Minute Entry for proceedings held before Judge Alison J. Nathan: Arraignment as to
Ghislaine Maxwell (1) Count 1s,2s,3s, 4s, 5s-6s held on 7/14/2020. Defendant
Ghislaine Maxwell present by video conference with attorney Mark Cohen present by
video conference, AUSA Alison Moe, Alex Rossmiller and Maurene Comey for the
government present by video conference, Pretrial Service Officer Lea Harmon present
by telephone and Court Reporter Kristine Caraannante. Defendant enters a plea of Not
Guilty to the S1 indictment. Trial set for July 12, 2021. See Order. Time is excluded
under the Speedy Trial Act from today until July 12, 2021. Bail is denied. Defendant is
| remanded. See Transcript. (jw) (Entered: 07/14/2020)</td></tr><tr><td>07/14/2020</td><td></td><td>Minute Entry for proceedings held before Judge Alison J. Nathan: Plea entered by
Ghislaine Maxwell (1) Count 1s,2s,3s, 4s, 5s-6s Not Guilty. (jw) (Entered: 07/14/2020)</td></tr><tr><td>07/14/2020</td><td>24</td><td>Waiver of Right to be Present at Criminal Proceeding as to Ghislaine Maxwell re:
Arraignment, Bail Hearing, Conference. (jw) (Entered: 07/14/2020)</td></tr><tr><td>07/15/2020</td><td>25</td><td>ORDER as to Ghislaine Maxwell. Initial non-electronic discovery, generally to
include search warrant applications and subpoena returns, is due by Friday, August 21,
2020. Completion of discovery, to include electronic materials, is due by Monday,
November 9, 2020. Motions are due by Monday, December 21, 2020. Motion
responses are due by Friday, January 22, 2021. Motion replies are due by Friday,
February 5, 2021. Trial is set for Monday, July 12, 2021 (Discovery due by
8/21/2020., Motions due by 12/21/2020) (Signed by Judge Alison J. Nathan on
7/15/20)(jw) (Entered: 07/15/2020)</td></tr><tr><td>07/21/2020</td><td>26</td><td>ORDER as to Ghislaine Maxwell: The Court has received a significant number of
letters and messages from non-parties that purport to be related to this case. These
submissions are either procedurally improper or irrelevant to the judicial function.
Therefore, they will not be considered or docketed. The Court will accord the same
treatment to any similar correspondence it receives in the future. SO ORDERED.
(Signed by Judge Alison J. Nathan on 7/21/2020) (Inl) (Entered: 07/21/2020)</td></tr><tr><td>07/21/2020</td><td>27</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Jeffrey S. Pagliuca
dated July 21, 2020 re: Local Criminal Rule 23.1. Document filed by Ghislaine
Maxwell. (Pagliuca, Jeffrey) (Entered: 07/21/2020)</td></tr><tr><td>07/23/2020</td><td>28</td><td>ORDER as to Ghislaine Maxwell: The Defense has moved for an order "prohibiting
the Government, its agents and counsel for witnesses from making extrajudicial
statements concerning this case." Dkt. No. 27 at 1. The Court firmly expects that
counsel for all involved parties will exercise great care to ensure compliance with this
Court's local rules, including Local Criminal Rule 23.1, and the rules of professional
responsibility. In light of this clear expectation, the Court does not believe that further
action is needed at this time to protect the Defendant's right to a fair trial by an
impartial jury. Accordingly, it denies the Defendant's motion without prejudice. But
the Court warns counsel and agents for the parties and counsel for potential witnesses
that going forward it will not hesitate to take appropriate action in the face of
violations of any relevant rules. The Court will ensure strict compliance with those
rules and will ensure that the Defendant's right to a fair trial will be safeguarded.
(Signed by Judge Alison J. Nathan on 7/23/2020) (ap) (Entered: 07/23/2020)</td></tr><tr><td>07/27/2020</td><td>29</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated July 27, 2020 re: Proposed Protective Order. Document filed by Ghislaine
Maxwell. (Attachments: # 1 Exhibit A (Proposed Protective Order))(Everdell,
Christian) (Entered: 07/27/2020)</td></tr><tr><td>07/27/2020</td><td>30</td><td>AFFIDAVIT of Christian R. Everdell by Ghislaine Maxwell. (Everdell, Christian)
(Entered: 07/27/2020)</td></tr><tr><td>07/27/2020</td><td>31</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
Alison Moe dated July 27, 2020 re: requesting until 5 p.m. tomorrow to respond to
defense counsel's letter, filed July 27, 2020 Document filed by USA. (Moe, Alison)</td></tr></table>

# Case 21-58, Document 1-2, 01/12/2021, 3011673, Page9 of 19

<table><tr><th></th><th></th><th>(Entered: 07/27/2020)</th></tr><tr><td>07/27/2020</td><td>32</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on 31 LETTER by USA as to
Ghislaine Maxwell addressed to Judge Alison J. Nathan from Alison Moe dated July
27, 2020 re: requesting until 5 p.m. tomorrow to respond to defense counsel's letter,
filed July 27, 2020. ENDORSEMENT: The Government's response to the Defense's
letter is due by 5 p.m. on July 28, 2020. The Defense may file a reply by 5 p.m. on
July 29, 2020. Before the Government's response is filed, the parties must meet and
confer by phone regarding this issue, and any response from the Government must
contain an affirmation that the parties have done so. SO ORDERED. (Responses due
by 7/28/2020. Replies due by 7/29/2020.) (Signed by Judge Alison J. Nathan on
7/27/2020) (Inl) (Entered: 07/27/2020)</td></tr><tr><td>07/28/2020</td><td>33</td><td>LETTER RESPONSE to Motion by USA as to Ghislaine Maxwell addressed to Judge
Alison J. Nathan from Alex Rossmiller dated July 28, 2020 re: 29 LETTER MOTION
addressed to Judge Alison J. Nathan from Christian R. Everdell dated July 27, 2020 re:
Proposed Protective Order .. (Attachments: #1 Exhibit A (proposed protective
order))(Rossmiller, Alex) (Entered: 07/28/2020)</td></tr><tr><td>07/28/2020</td><td>34</td><td>AFFIDAVIT of Alex Rossmiller by USA as to Ghislaine Maxwell. (Rossmiller, Alex)
(Entered: 07/28/2020)</td></tr><tr><td>07/29/2020</td><td>35</td><td>LETTER REPLY TO RESPONSE to Motion by Ghislaine Maxwell addressed to
Judge Alison J. Nathan from Christian R. Everdell dated July 29, 2020 re 29 LETTER
MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell dated July
27, 2020 re: Proposed Protective Order .. (Everdell, Christian) (Entered: 07/29/2020)</td></tr><tr><td>07/30/2020</td><td>36</td><td>PROTECTIVE ORDER as to Ghislaine Maxwell...regarding procedures to be
followed that shall govern the handling of confidential material. SO ORDERED:
(Signed by Judge Alison J. Nathan on 7/30/2020)(bw) (Entered: 07/31/2020)</td></tr><tr><td>07/30/2020</td><td>37</td><td>MEMORANDUM OPINION &amp; ORDER as to Ghislaine Maxwell. Both parties have
asked for the Court to enter a protective order. While they agree on most of the
language, two areas of dispute have emerged. First, Ms. Maxwell seeks language
allowing her to publicly reference alleged victims or witnesses who have spoken on
the public record to the media or in public fora, or in litigation relating to Ms. Maxwell
or Jeffrey Epstein. Second, Ms. Maxwell seeks language restricting potential
Government witnesses and their counsel from using discovery materials for any
purpose other than preparing for the criminal trial in this action. The Government has
proposed contrary language on both of these issues. For the following reasons, the
Court adopts the Government's proposed protective order Under Federal Rule of
Criminal Procedure 16(d)(1), "[a]t any time the court may, for good cause, deny,
restrict, or defer discovery or inspection, or grant other appropriate relief." The good
cause standard "requires courts to balance several interests, including whether
| dissemination of the discovery materials inflicts hazard to others... whether the
imposition of the protective order would prejudice the defendant," and "the public's
interest in the information." United States v. Smith, 985 F. Supp. 2d 506, 522
|(S.D.N.Y. 2013). The party seeking to restrict disclosure bears the burden of showing
good cause. Cf. Gambale v. Deutsche Bank AG, 377 F.3d 133, 142 (2d Cir. 2004).
| First, the Court finds that the Government has met its burden of showing good cause
with regard to restricting the ability of Ms. Maxwell to publicly reference alleged
victims and witnesses other than those who have publicly identified themselves in this
litigation. As a general matter, it is undisputed that there is a strong and specific
interest in protecting the privacy of alleged victims and witnesses in this case that
supports restricting the disclosure of their identities. Dkt. No. 29 at 3 (acknowledging
that as a baseline the protective order should "prohibit[] Ms. Maxwell, defense
counsel, and others on the defense team from disclosing or disseminating the identity
of any alleged victim or potential witness referenced in the discovery materials"); see
also United States v. Corley, No. 13-cr-48, 2016 U.S. Dist. LEXIS 194426, at *11
(S.D.N.Y. Jan. 15, 2016). The Defense argues this interest is significantly diminished
for individuals who have spoken on the public record about Ms. Maxwell or Jeffrey
Epstein, because they have voluntarily chosen to identify themselves. But not all
accusations or public statements are equal. Deciding to participate in or contribute to a
criminal investigation or prosecution is a far different matter than simply making a
public statement "relating to" Ms. Maxwell or Jeffrey Epstein, particularly since such a
statement might have occurred decades ago and have no relevance to the charges in</td></tr></table>

# Case 21-58, Document 1-2, 01/12/2021, 3011673, Page 10 of 19

<table><tr><th></th><th></th><th>this case. These individuals still maintain a significant privacy interest that must be
safeguarded. The exception the Defense seeks is too broad and risks undermining the
protections of the privacy of witnesses and alleged victims that is required by law. In
contrast, the Government's proffered language would allow Ms. Maxwell to publicly
reference individuals who have spoken by name on the record in this case. It also
allows the Defense to "referenc[e] the identities of individuals they believe may be
relevant... to Potential Defense Witnesses and their counsel during the course of the
investigation and preparation of the defense case at trial." Dkt. No. 33-1, 5. This
proposal adequately balances the interests at stake. And as the Government's letter
notes, see Dkt. No. 33 at 4, to the extent that the Defense needs an exception to the
protective order for a specific investigative purpose, they can make applications to the
Court on a case-by-case basis. Second, restrictions on the ability of potential
witnesses and their counsel to use discovery materials for purposes other than
preparing for trial in this case are unwarranted. The request appears unprecedented
despite the fact that there have been many high-profile criminal matters that had
related civil litigation. The Government labors under many restrictions including Rule
6(e) of the Federal Rules of Criminal Procedure, the Privacy Act of 1974, and other
policies of the Department of Justice and the U.S. Attorney's Office for the Southern
District of New York, all of which the Court expects the Government to scrupulously
follow. Furthermore, the Government indicates that it will likely only provide potential
witnesses with materials that those witnesses already have in their possession. See Dkt.
No. 33 at 6. And of course, those witnesses who do testify at trial would be subject to
examination on the record as to what materials were provided or shown to them by the
Government. Nothing in the Defense's papers explains how its unprecedented
proposed restriction is somehow necessary to ensure a fair trial. For the foregoing
reasons, the Court adopts the Government's proposed protective order, which will be
entered on the docket. This resolves Dkt. No. 29. SO ORDERED. (Signed by Judge
Alison J. Nathan on 7/30/2020)(bw) (Entered: 07/31/2020)</th></tr><tr><td>08/10/2020</td><td>38</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated August 10, 2020 re: Discovery Disclosure and Access. Document filed by
Ghislaine Maxwell. (Everdell, Christian) (Entered: 08/10/2020)</td></tr><tr><td>08/10/2020</td><td>39</td><td>AFFIDAVIT of Christian R. Everdell by Ghislaine Maxwell. (Everdell, Christian)
(Entered: 08/10/2020)</td></tr><tr><td>08/11/2020</td><td>40</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 38 LETTER MOTION
addressed to Judge Alison J. Nathan from Christian R. Everdell dated August 10, 2020
re: Discovery Disclosure and Access. ENDORSEMENT: The Government is hereby
| ORDERED to respond to the Defendant's letter motion by Thursday, August 13, 2020.
The Defendant's reply, if any, is due on or before Monday, August 17, 2020.
(Responses due by 8/13/2020. Replies due by 8/17/2020) (Signed by Judge Alison J.
Nathan on 8/11/2020) (ap) (Entered: 08/11/2020)</td></tr><tr><td>08/13/2020</td><td>41</td><td>LETTER RESPONSE in Opposition by USA as to Ghislaine Maxwell addressed to
Judge Alison J. Nathan from Alex Rossmiller dated August 13, 2020 re: 38 LETTER
MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell dated
August 10, 2020 re: Discovery Disclosure and Access .. (Rossmiller, Alex) (Entered:
08/13/2020)</td></tr><tr><td>08/17/2020</td><td>42</td><td>LETTER REPLY TO RESPONSE to Motion by Ghislaine Maxwell addressed to
Judge Alison J. Nathan from Christian R. Everdell dated August 17, 2020 re 38
LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated August 10, 2020 re: Discovery Disclosure and Access .. (Everdell, Christian)
(Entered: 08/17/2020)</td></tr><tr><td>08/17/2020</td><td>43</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Jeffrey S. Pagliuca
dated August 17, 2020 re: Request for Permission to Submit Letter Motion in Excess
of Three Pages. Document filed by Ghislaine Maxwell. (Pagliuca, Jeffrey) (Entered:
08/17/2020)</td></tr><tr><td>08/18/2020</td><td>44</td><td>ORDER as to Ghislaine Maxwell: On August 17, 2020, the Defendant filed a letter
motion seeking a modification of this Court's Protective Order, which the Court
entered on July 30, 2020. Defendant also moves to file that letter motion under seal.
The Governments opposition to Defendant's letter motion is hereby due Friday, August
21 at 12 p.m. The Defendant's reply is due on Monday, August 24 at 12 p.m. The</td></tr></table>

# Case 21-58, Document 1-2, 01/12/2021, 3011673, Page11 of 19

<table><tr><th></th><th></th><th>parties shall propose redactions to the letter briefing on this issue. Alternatively, the
parties shall provide support and argument for why the letter motions should be sealed
in their entirety. SO ORDERED. (Responses due by 8/21/2020. Replies due by
8/24/2020.) (Signed by Judge Alison J. Nathan on 8/18/2020) (Inl) (Entered:
08/18/2020)</th></tr><tr><td>08/20/2020</td><td>45</td><td>NOTICE OF ATTORNEY APPEARANCE Lara Elizabeth Pomerantz appearing for
USA. (Pomerantz, Lara) (Entered: 08/20/2020)</td></tr><tr><td>08/20/2020</td><td>50</td><td>SEALED DOCUMENT placed in vault. (mhe) (Entered: 08/27/2020)</td></tr><tr><td>08/21/2020</td><td>46</td><td>LETTER RESPONSE in Opposition by USA as to Ghislaine Maxwell addressed to
Judge Alison J. Nathan from Maurene Comey dated August 21, 2020 re: 43 LETTER
MOTION addressed to Judge Alison J. Nathan from Jeffrey S. Pagliuca dated August
17, 2020 re: Request for Permission to Submit Letter Motion in Excess of Three Pages
.. (Rossmiller, Alex) (Entered: 08/21/2020)</td></tr><tr><td>08/21/2020</td><td>47</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
Maurene Comey dated August 21, 2020 re: Proposed redactions to letter briefing, in
response to the Court's Order of August 18, 2020 Document filed by USA.
(Rossmiller, Alex) (Entered: 08/21/2020)</td></tr><tr><td>08/24/2020</td><td>48</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Laura A. Menninger
dated August 24, 2020 re: Request to File Under Seal: Proposed Redactions to Request
to Modify Protective Order and Reply in Support Thereof. Document filed by
Ghislaine Maxwell. (Menninger, Laura) (Entered: 08/24/2020)</td></tr><tr><td>08/25/2020</td><td>49</td><td>MEMORANDUM OPINION AND ORDER: denying without prejudice 38 LETTER
MOTION as to Ghislaine Maxwell (1). On August 10, 2020, the Defendant filed a
letter motion related to two issues. Dkt. No. 38. First, the Defendant seeks an order
directing the Government to disclose to defense counsel immediately the identities of
the three alleged victims referenced in the indictment. Second, the Defendant seeks an
order directing the Bureau of Prisons ("BOP") to release the Defendant into the general
population and to provide her with increased access to the discovery materials. For the
reasons that follow, Defendant's requests are DENIED without prejudice.... [See this
Memorandum Opinion And Order]... III. Conclusion: For the reasons stated above,
Defendant's requests contained in Dkt. No. 38 are DENIED without prejudice.
Following the close of discovery, the parties shall meet and confer on an appropriate
schedule for pre-trial disclosures, including the disclosure of § 3500 material, exhibit
lists, and witness lists, taking into account all relevant factors. The Government is
hereby ORDERED to submit written status updates every 90 days detailing any
material changes to the conditions of Ms. Maxwell's confinement, with particular
emphasis on her access to legal materials and ability to communicate with defense
counsel. SO ORDERED. (Signed by Judge Alison J. Nathan on 8/25/2020) (bw)
(Entered: 08/25/2020)</td></tr><tr><td>09/02/2020</td><td>51</td><td>MEMORANDUMOPINION AND ORDER as to Ghislaine Maxwell: On August 17,
2020, Defendant Ghislaine Maxwell filed a sealed letter motion seeking an Order
modifying the protective order in this case. Specifically, she sought a Court order
allowing her to file under seal in certain civil cases ("Civil Cases") materials
("Documents") that she received in discovery from the Government in this case. She
also sought permission to reference, but not file, other discovery material that the
Government produced in this case. For the reasons that follow, Defendant's requests
are DENIED. SO ORDERED. (Signed by Judge Alison J. Nathan on 9/2/2020)(See
MEMORANDUM OPINION AND ORDER as set forth) (Inl) (Entered: 09/02/2020)</td></tr><tr><td>09/02/2020</td><td>52</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan, from Jeffrey S.
Pagliuca dated 8/17/2020 re: Defense counsel writes with redacted request to modify
protective order. (ap) (Entered: 09/02/2020)</td></tr><tr><td>09/04/2020</td><td>55</td><td>NOTICE OF APPEAL by Ghislaine Maxwell from 51 Memorandum &amp; Opinion.
Filing fee $ 505.00, receipt number 465401266036. (tp) (Entered: 09/09/2020)</td></tr><tr><td>09/08/2020</td><td>53</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan dated 8/24/2020
re: Proposed Redactions to Request to Modify Protective Order. (jbo) (Entered:
09/08/2020)</td></tr></table>

# Case 21-58, Document 1-2, 01/12/2021, 3011673, Page 12 of 19

<table><tr><th>09/08/2020</th><th>54</th><th>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan dated 8/24/2020
re: Reply in Support of Request to Modify Protective Order. (jbo) (Entered:
09/08/2020)</th></tr><tr><td>09/09/2020</td><td></td><td>Transmission of Notice of Appeal and Certified Copy of Docket Sheet as to Ghislaine
Maxwell to US Court of Appeals re: 55 Notice of Appeal. (tp) (Entered: 09/09/2020)</td></tr><tr><td>09/09/2020</td><td></td><td>Appeal Record Sent to USCA (Electronic File). Certified Indexed record on Appeal
Electronic Files as to Ghislaine Maxwell re: 55 Notice of Appeal were transmitted to
the U.S. Court of Appeals. (tp) (Entered: 09/09/2020)</td></tr><tr><td>09/10/2020</td><td>56</td><td>SEALED DOCUMENT placed in vault. (dn) (Entered: 09/11/2020)</td></tr><tr><td>09/10/2020</td><td>57</td><td>SEALED DOCUMENT placed in vault. (dn) (Entered: 09/11/2020)</td></tr><tr><td>09/24/2020</td><td>58</td><td>SEALED DOCUMENT placed in vault. (mhe) (Entered: 09/24/2020)</td></tr><tr><td>10/05/2020</td><td>59</td><td>NOTICE OF ATTORNEY APPEARANCE: Bobbi C Sternheim appearing for
Ghislaine Maxwell. Appearance Type: Retained. (Sternheim, Bobbi) (Entered:
10/05/2020)</td></tr><tr><td>10/06/2020</td><td>60</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated October 6, 2020 re:
Request to Delay Disclosure Document filed by USA. (Comey, Maurene) (Entered:
10/06/2020)</td></tr><tr><td>10/06/2020</td><td>61</td><td>AFFIDAVIT of Maurene Comey by USA as to Ghislaine Maxwell. (Comey, Maurene)
(Entered: 10/06/2020)</td></tr><tr><td>10/07/2020</td><td>62</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 60 Accordingly, the
Government respectfully requests that the Court approve the Government's request to
delay disclosure of these Materials...ENDORSEMENT...The Defendant shall file any
opposition to the Government's request by October 14, 2020. The Government's reply,
if any, is due by October 20, 2020. SO ORDERED. (Government Replies due by
10/20/2020., Defendant Responses due by 10/14/2020) (Signed by Judge Alison J.
Nathan on 10/7/20)(jw) (Entered: 10/07/2020)</td></tr><tr><td>10/07/2020</td><td>63</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAs Maurene Comey, Alison Moe, and Lara Pomerantz dated October 7, 2020 re:
Review of Investigative Files from Other Offices and Agencies Document filed by
USA. (Comey, Maurene) (Entered: 10/07/2020)</td></tr><tr><td>10/14/2020</td><td>64</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated October 14, 2020 re: Response to 60 LETTER addressed to Judge
Alison J. Nathan from USA dated October 6, 2020 re: Request to Delay Disclosure.
(Everdell, Christian) (Entered: 10/14/2020)</td></tr><tr><td>10/20/2020</td><td>65</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated October 20, 2020 re:
Reply Letter in Further Support of Request to Delay Disclosure Document filed by
USA. (Comey, Maurene) (Entered: 10/20/2020)</td></tr><tr><td>10/23/2020</td><td>66</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Jeffrey S.
Pagliuca dated October 23, 2020 re: Response to the Governments October 7, 2020
letter (Pagliuca, Jeffrey) (Entered: 10/23/2020)</td></tr><tr><td>10/30/2020</td><td>67</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAs Maurene Comey, Alison Moe, and Lara Pomerantz dated October 30, 2020 re:
Reply to Defense's October 23, 2020 Letter Document filed by USA. (Comey,
Maurene) (Entered: 10/30/2020)</td></tr><tr><td>11/05/2020</td><td>68</td><td>ORDER as to Ghislaine Maxwell: This Order is entered, pursuant to Federal Rule of
Criminal Procedure 5(f) and the Due Process Protections Act, Pub. L. No 116182, 134
Stat. 894 (Oct. 21, 2020), to confirm the Government's disclosure obligations under
Brady v. Maryland, 373 U.S. 83 (1963), and its progeny, and to summarize the
possible consequences of violating those obligations. (Signed by Judge Alison J.
Nathan on 11/5/2020) (See ORDER set forth) (ap) (Entered: 11/05/2020)</td></tr></table>

# Case 21-58, Document 1-2, 01/12/2021, 3011673, Page13 of 19

<table><tr><th>11/06/2020</th><th>69</th><th>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated November 6, 2020
re: Request to Extend Discovery Deadline for Portion of Electronic Discovery
Document filed by USA. (Comey, Maurene) (Entered: 11/06/2020)</th></tr><tr><td>11/06/2020</td><td>70</td><td>AFFIDAVIT of Maurene Comey by USA as to Ghislaine Maxwell. (Comey, Maurene)
(Entered: 11/06/2020)</td></tr><tr><td>11/09/2020</td><td>71</td><td>MANDATE of USCA (Certified Copy) as to Ghislaine Maxwell re: 55 Notice of
Appeal. USCA Case Number 20-3061-cr. UPON DUE CONSIDERATION
WHEREOF, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that the
motion to consolidate is DENIED and the appeal is DISMISSED for want of
jurisdiction.. Catherine O'Hagan Wolfe, Clerk USCA for the Second Circuit. Issued As
Mandate: 11/09/2020. (nd) (Entered: 11/09/2020)</td></tr><tr><td>11/09/2020</td><td>72</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on 69 LETTER by USA as to
Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene
Comey, Alison Moe, and Lara Pomerantz dated November 6, 2020 re: Request to
Extend Discovery Deadline for Portion of Electronic Discovery. ENDORSEMENT:
The Court hereby extends the deadline for the Government's production of electronic
discovery from November 9, 2020 to November 23, 2020. The Court also grants the
parties' request for an extension of the motions deadlines as follows: the Defendant's
motions are due by January 11, 2021, the Government's responses are due by February
12, 2021, and any replies are due by February 19, 2021. SO ORDERED. (Discovery
due by 11/23/2020. Motions due by 1/11/2021. Responses due by 2/12/2021. Replies
due by 2/19/2021.) (Signed by Judge Alison J. Nathan on 11/9/2020) (Inl) (Entered:
11/10/2020)</td></tr><tr><td>11/18/2020</td><td>73</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 60 Letter filed by USA as
to Ghislaine Maxwell re: The Government respectfully requests that the Court approve
the Government's request to delay disclosure of these
Materials...ENDORSEMENT...There is no dispute that the materials referenced in the
Government's letter will be turned over to the defense. The Government has indicated
that it will do so. The only dispute, then, relates to the timing of such disclosure. See
Dkt. Nos. 64, 65. Because the Government has articulated plausible reasons for some
delay of disclosure, see Dkt. No. 65 at 4, the Court grants the Government's request to
delay disclosure. However, the Governments proposal to delay disclosure until 8
weeks in advance of trial is insufficient. In order to ensure that the defense can
adequately prepare for trial, the Government shall produce the referenced materials,
which are not voluminous, to the defense by March 12, 2021. Disclosure of the
materials will of course be subject to the protective order entered by the Court, see
Dkt. No. 36. (Government Responses due by 3/12/2021) (Signed by Judge Alison J.
Nathan on 11/18/20)(jw) (Entered: 11/18/2020)</td></tr><tr><td>11/23/2020</td><td>74</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated November 23, 2020
re: Update Regarding Conditions of Confinement Document filed by USA. (Comey,
Maurene) (Entered: 11/23/2020)</td></tr><tr><td>11/24/2020</td><td>75</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C.
Sternheim dated 11/24/2020 re: Response to 90-day MDC conditions report
(Sternheim, Bobbi) (Entered: 11/24/2020)</td></tr><tr><td>11/24/2020</td><td>76</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 75 LETTER by Ghislaine
Maxwell addressed to Judge Alison J. Nathan from Bobbi C. Sternheim dated
11/24/2020 re: Response to 90-day MDC conditions report. ENDORSEMENT: The
parties are hereby ORDERED to meet and confer regarding Defendant's request that
Warden Heriberto Tellez directly address Defendant's concerns regarding the
conditions of her detention. The parties shall jointly submit a status update within one
week of this Order. (Signed by Judge Alison J. Nathan on 11/24/2020) (ap) (Entered:
11/24/2020)</td></tr><tr><td>12/01/2020</td><td>77</td><td>ORDER as to Ghislaine Maxwell. On November 25, 2020, the Defendant filed a letter
request under seal. On November 30, 2020, she filed a second letter request in which
she proposed redactions on both letters. The Government is hereby ORDERED to
respond to the Defendant's November 25, 2020 letter request and to the request for
proposed redactions by no later than December 2, 2020. The letters shall be</td></tr></table>

# Case 21-58, Document 1-2, 01/12/2021, 3011673, Page14 of 19

<table><tr><th></th><th></th><th>temporarily sealed while the Court resolves the redaction request. SO ORDERED.
(Signed by Judge Alison J. Nathan on 12/1/2020)(bw) (Entered: 12/01/2020)</th></tr><tr><td>12/01/2020</td><td>78</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated December 1, 2020
re: Joint Letter regarding Conditions of Confinement Document filed by USA.
(Pomerantz, Lara) (Entered: 12/01/2020)</td></tr><tr><td>12/02/2020</td><td>79</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 78 LETTER by USA
addressed to Judge Alison J. Nathan from AUSAS Maurene Comey, Alison Moe, and
Lara Pomerantz dated December 1, 2020 re: Joint Letter regarding Conditions of
Confinement. ENDORSEMENT: MDC legal counsel shall submit their letter to the
Court by December 4, 2020. Upon review of that letter, the Court will determine
whether any additional information is required, either orally or in writing. SO
ORDERED. (Signed by Judge Alison J. Nathan on 12/2/2020)(bw) (Entered:
12/02/2020)</td></tr><tr><td>12/02/2020</td><td>80</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated December 2, 2020
re: Defense Requests for Sealing Document filed by USA. (Comey, Maurene)
(Entered: 12/02/2020)</td></tr><tr><td>12/03/2020</td><td>81</td><td>ORDER as to Ghislaine Maxwell. On November 25, 2020, counsel for Defendant
Ghislaine Maxwell filed a letter request seeking an in camera conference for the
presentation of a renewed motion for release on bail and a request to seal the
November 25, 2020 letter in its entirety. The Court required justification for the
sealing request. On November 30, 2020, the defense counsel filed a second letter no
longer fully pressing the unsupported request to file the letter entirely under seal and
instead proposing redactions to both the November 25th and November 30th letters.
The Government has indicated that it does not oppose the redactions. Dkt. No. 80.
After due consideration, the Court will adopt the Defendant's proposed redactions,
which are consented to by the Government. The Court's decision is guided by the
three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of
Onondaga, 435 F.3d 110 (2d Cir. 2006). Under this test, the Court must: (i) determine
whether the documents in question are "judicial documents;" (ii) assess the weight of
the common law presumption of access to the materials; and (iii) balance competing
considerations against the presumption of access. Id. at 11920. "Such countervailing
factors include but are not limited to 'the danger of impairing law enforcement or
judicial efficiency' and 'the privacy interests of those resisting disclosure."" Id. at 120
(quoting United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995) ("Amodeo II")).
The proposed redactions satisfy this test. First, the Court finds that the Defendant's
letter motions are "relevant to the performance of the judicial function and useful in
the judicial process," thereby qualifying as a "judicial document" for purposes of the
first element of the Lugosch test. United States v. Amodeo ("Amodeo I"), 44 F.3d 141,
145 (2d Cir. 1995). And while the Court assumes that the common law presumption of
access attaches, in balancing competing considerations against the presumption of
access, the Court finds that the arguments the Defendant has put forthincluding, most
notably, the privacy interests of the individuals referenced in the lettersfavor her
proposed and tailored redactions. The Defendant is hereby ORDERED to docket the
redacted versions of the two letters by December 4, 2020. For the reasons outlined in
the Government's letter dated December 2, 2020, Dkt. No. 80, the Court DENIES the
Defendant's request for an in camera conference. In order to protect the privacy
interests referenced in the Defendant's November 25, 2020 letter, the Court will permit
the Defendant to make her submission in writing and to propose narrowly tailored
redactions. The parties are hereby ORDERED to meet and confer and to jointly
prepare a briefing schedule for the Defendant's forthcoming renewed motion for
release on bail. SO ORDERED. (Signed by Judge Alison J. Nathan on 12/3/2020)(bw)
(Entered: 12/03/2020)</td></tr><tr><td>12/03/2020</td><td>82</td><td>SEALED DOCUMENT placed in vault. (jus) (Entered: 12/03/2020)</td></tr><tr><td>12/03/2020</td><td>83</td><td>SEALED DOCUMENT placed in vault. (jus) (Entered: 12/03/2020)</td></tr><tr><td>12/03/2020</td><td>84</td><td>SEALED DOCUMENT placed in vault. (jus) (Entered: 12/03/2020)</td></tr></table>

# Case 21-58, Document 1-2, 01/12/2021, 3011673, Page15 of 19

<table><tr><th>12/04/2020</th><th>85</th><th>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated December 4, 2020 re: Briefing Schedule (Everdell, Christian) (Entered:
12/04/2020)</th></tr><tr><td>12/04/2020</td><td>86</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated 11/25/2020 re: Sealing (Everdell, Christian) (Entered: 12/04/2020)</td></tr><tr><td>12/04/2020</td><td>87</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
| Everdell dated 11/30/2020 re: Sealing (Everdell, Christian) (Entered: 12/04/2020)</td></tr><tr><td>12/07/2020</td><td>88</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Sophia
Papapetru and John Wallace dated 12/4/20 re: This letter is written in response to your
order dated December 2, 2020, concerning Ghislaine Maxwell, Reg. 02879-509., an
inmate currently confined at the Metropolitan Detention center in Brooklyn, New
York. You expressed various concerns regarding Ms. Maxwells confinement and
well-being. (jw) (Entered: 12/07/2020)</td></tr><tr><td>12/07/2020</td><td>89</td><td>ORDER as to Ghislaine Maxwell re: 85 Letter filed by Ghislaine Maxwell. The Court
is in receipt of the Defendant's December 4, 2020 letter, Dkt. No. 85, and hereby sets
the following schedule: The Defendants submission is due December 8, 2020; The
Government's response is due December 16, 2020; The Defendant's reply is due
December 18, 2020. After reviewing these submissions, the Court will determine
whether a hearing on the renewed bail motion is necessary. The Court grants the
Defendants request that the Government shall file its submission under seal with
proposed redactions. Any objections to proposed redactions are due within 24 hours
after any brief has been filed. Finally, the Defendant is granted leave to file a motion
not to exceed 40 pages. The Governments response shall also be limited to 40 pages.
The Defendant's reply shall not exceed 10 pages (Defendant submission due by
12/8/2020., Defendant Replies due by 12/18/2020., Government Responses due by
12/16/2020) (Signed by Judge Alison J. Nathan on 12/7/20)(jw) (Entered: 12/07/2020)</td></tr><tr><td>12/07/2020</td><td>90</td><td>ENDORSED LETTER as to Ghislaine Maxwell addressed to Judge Alison J. Nathan
from Mark S. Cohen and Christian R. Everdell dated 11/25/20 re: On behalf of my
client, Ghislaine Maxwell, we plan to file a Renewed Motion for Release on Bail (the
"Motion") and respectfully request an in camera conference, with all counsel present,
to address the appropriate procedures for the filing and consideration of the Motion.
For the reasons explained below, we intend to request, pursuant to Fed. R. Crim. P.
49.1(d), that the Court permit the filing of portions of the Motion and certain
supporting materials under seal and require that any responsive materials be filed
under seal....ENDORSEMENT: The Court sees no basis for the sealing of this letter.
On or before December 2, 2020, Defendant shall justify why this letter should be
sealed (or redacted). Alternatively, the Defendant may file the letter on the public
docket by that date. The Court will take no action on the request pending resolution of
the initial sealing question. The Defendant's letter and this memorandum endorsement
will be temporarily sealed pending resolution of the sealing request. (Signed by Judge
Alison J. Nathan on 11/25/20)(jw) (Entered: 12/07/2020)</td></tr><tr><td>12/07/2020</td><td>91</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C.
Sternheim dated 12/07/2020 re: Response to MDC Report to Court re: conditions
(Sternheim, Bobbi) (Entered: 12/07/2020)</td></tr><tr><td>12/08/2020</td><td>92</td><td>ORDER as to Ghislaine Maxwell: On December 4, 2020, the Court received a letter
from MDC legal counsel responding to the concerns that the Defendant raised in her
November 24, 2020 letter. See Dkt. Nos. 75, 88; see also Dkt. No. 78. The Defendant
responded to the MDC legal counsel's letter on December 7, 2020, reiterating her
request that the Court summon Warden Heriberto Tellez to personally respond to
questions from the Court regarding the Defendant's conditions of confinement. See
Dkt. No. 91. Having carefully reviewed the parties' submissions, along with the MDC
legal counsel's December 4, 2020 letter, the Court DENIES the Defendant's request to
summon the Warden to personally appear and respond to questions. This resolves Dkt.
No. 75. Notwithstanding this, as originally provided in Dkt. No. 49, the Government
shall continue to submit written status updates detailing any material changes to the
conditions of Ms. Maxwell's confinement, with particular emphasis on her access to
legal materials, including legal mail and email, and her ability to communicate with
defense counsel. The updates shall also include information on the frequency of
searches of the Defendant. The Court hereby ORDERS the Government to submit
these written updates every 60 days. Furthermore, the Government shall take all</td></tr></table>

# Case 21-58, Document 1-2, 01/12/2021, 3011673, Page16 of 19

<table><tr><th></th><th></th><th>necessary steps to ensure that the Defendant continues to receive adequate access to
her legal materials and her ability to communicate with defense counsel. (Signed by
Judge Alison J. Nathan on 12/8/2020) (ap) (Entered: 12/08/2020)</th></tr><tr><td>12/10/2020</td><td>93</td><td>TRANSCRIPT of Proceedings as to Ghislaine Maxwell re: Conference held on
7/14/2020 before Judge Alison J. Nathan. Court Reporter/Transcriber: Kristen
Carannante, (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 12/31/2020. Redacted Transcript Deadline set for 1/11/2021. Release of
Transcript Restriction set for 3/10/2021. (McGuirk, Kelly) (Entered: 12/10/2020)</td></tr><tr><td>12/10/2020</td><td>94</td><td>NOTICE OF FILING OF OFFICIAL TRANSCRIPT as to Ghislaine Maxwell. Notice
is hereby given that an official transcript of a Conference proceeding held on
7/14/2020 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.... (McGuirk, Kelly) (Entered: 12/10/2020)</td></tr><tr><td>12/14/2020</td><td>95</td><td>ORDER as to Ghislaine Maxwell: On December 8, 2020, Defendant Ghislaine
Maxwell filed her renewed application for bail under seal with proposed redactions, in
accordance with this Court's December 7, 2020 Order, see Dkt. No. 89. The
Government did not file any opposition to the Defendant's proposed redactions. After
due consideration, the Court will adopt the Defendant's proposed redactions. The
Court's decision to adopt those redactions is guided by the three-part test articulated
by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir.
2006). Under this test, the Court must: (i) determine whether the documents in
question are "judicial documents;" (ii) assess the weight of the common law
presumption of access to the materials; and (iii) balance competing considerations
against the presumption of access. Id. at 11920. "Such countervailing factors include
but are not limited to the danger of impairing law enforcement or judicial efficiency'
and 'the privacy interests of those resisting disclosure." Id. at 120 (quoting United
States v. Amodeo, 71 F.3d 1044, 1048 (2d Cir. 1995) ("Amodeo II")). The proposed
redactions satisfy this test. The Court finds that Defendant's letter motions are
"relevant to the performance of the judicial function and useful in the judicial process,'
thereby qualifying as a "judicial document" for purposes of the first element of the
Lugosch test. United States v. Amodeo ("Amodeo I"), 44 F.3d 141, 145 (2d Cir. 1995).
And the Court also finds that the common law presumption of access attaches. Id. at
146; see also Nixon v. Warner Comme'ns, Inc., 435 U.S. 589, 602 (1978).
Nevertheless, in balancing competing considerations against the presumption of
access, the Court finds that the redactions are narrowly tailored to properly guard the
privacy interests of the individuals referenced in the Defendant's submission and in the
corresponding exhibits The Defendant is hereby ORDERED to docket the redacted
documents and corresponding exhibits. (Signed by Judge Alison J. Nathan on
12/14/2020) (ap) (Entered: 12/14/2020)</td></tr><tr><td>12/14/2020</td><td>96</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated December 8, 2020 re: Cover Letter for Renewed Bail Application
(Everdell, Christian) (Entered: 12/14/2020)</td></tr><tr><td>12/14/2020</td><td>97</td><td>MEMORANDUM OF LAW in Support by Ghislaine Maxwell re: Renewed Motion
for Bail. (Attachments: # 1 Exhibit A, #2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5
Exhibit E, #6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, #2 Exhibit I, # 10 Exhibit J, #
11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16
Exhibit P, #17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit
U, #22 Exhibit V, # 23 Exhibit W, # 24 Exhibit X)(Everdell, Christian) (Entered:
12/14/2020)</td></tr><tr><td>12/17/2020</td><td>98</td><td>NOTICE OF ATTORNEY APPEARANCE Andrew Rohrbach appearing for USA.
(Rohrbach, Andrew) (Entered: 12/17/2020)</td></tr><tr><td>12/18/2020</td><td>99</td><td>ORDER as to Ghislaine Maxwell: On December 16, 2020, the Government filed its
opposition to Defendant Ghislaine Maxwell's renewed application for bail. In
accordance with this Court's December 7, 2020 Order, see Dkt. No. 89, the
Government filed its materials under seal and proposed narrowly tailored redactions on</td></tr></table>

# Case 21-58, Document 1-2, 01/12/2021, 3011673, Page 17 of 19

<table><tr><th></th><th></th><th>those materials. The Defendant did not file any opposition to the Government's
proposed redactions. The Court will adopt the Government's proposed redactions after
applying the three-part test articulated by the Second Circuit in Lugosch v. Pyramid
Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Under this test, the Court must: (i)
determine whether the documents in question are "judicial documents;" (ii) assess the
weight of the common law presumption access to the materials; and (iii) balance
competing considerations against the presumption of access. Id. at 11920. "Such
countervailing factors include but are not limited to 'the danger of impairing law
enforcement or judicial efficiency' and 'the privacy interests of those resisting
disclosure."" Id. at 120 (quoting United States v. Amodeo ("Amodeo II"), 71 F.3d
1044, 1050 (2d Cir. 1995)). The proposed redactions satisfy this test. The Court finds
that the Governments submissions are "relevant to the performance of the judicial
function and useful in the judicial process," thereby qualifying as a "judicial
document" for purposes of the first element of the Lugosch test. United States v.
Amodeo ("Amodeo I"), 44 F.3d 141, 145 (2d Cir. 1995). And the Court also finds that
the common law presumption of access attaches. Id. at 146; see also Nixon v. Warner
Comme'ns, Inc., 435 U.S. 589, 602 (1978). Nevertheless, the proposed redactions are
narrowly tailored to serve substantial interests, including, most importantly, third
parties' personal privacy interests. See Under Seal v. Under Seal, 273 F. Supp. 3d 460
467 (S.D.N.Y.2017). The Government is hereby ORDERED to docket the redacted
documents and corresponding exhibits by no later than December 18, 2 (Signed by
Judge Alison J. Nathan on 12/18/2020) (ap) (Entered: 12/18/2020)</th></tr><tr><td>12/18/2020</td><td>100</td><td>MEMORANDUM OF LAW in Opposition by USA as to Ghislaine Maxwell Renewed
Bail Motion. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Comey, Maurene) (Entered:
12/18/2020)</td></tr><tr><td>12/23/2020</td><td>101</td><td>ORDER as to Ghislaine Maxwell: On December 18, 2020, the Defendant filed her
reply to the Government's opposition to her renewed application for bail. In
accordance with this Court's December 7, 2020 Order, see Dkt. No. 89, she filed these
materials under seal and proposed narrowly tailored redactions on those materials. The
Government did not file any opposition to the Defendant's proposed redactions. The
Court will adopt the Defendant's proposed redactions after applying the three-part test
articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d
110 (2d Cir. 2006). Under this test, the Court must: (i) determine whether the
documents in question are "judicial documents;" (ii) assess the weight of the common
law presumption of access to the materials; and (iii) balance competing considerations
against the presumption of access. Id. at 11920. "Such countervailing factors include
but are not limited to 'the danger of impairing law enforcement or judicial efficiency'
and 'the privacy interests of those resisting disclosure." Id. at 120 (quoting United
States v. Amodeo ("Amodeo II"), 71 F.3d 1044, 1050 (2d Cir. 1995)). The proposed
redactions satisfy this test. The Court finds that the Defendant's submissions are
"relevant to the performance of the judicial function and useful in the judicial process,'
thereby qualifying as a "judicial document" for purposes of the first element of the
Lugosch test. United States v. Amodeo ("Amodeo Î"), 44 F.3d 141, 145 (2d Cir. 1995).
And the Court also finds that the common law presumption of access attaches. Id. at
146; see also Nixon v. Warner Comme'ns, Inc., 435 U.S. 589, 602 (1978). As with the
redactions to her renewed motion for bail, the proposed redactions here are narrowly
tailored to serve substantial interests, including, most importantly, third parties
personal privacy interests. See Under Seal v. Under Seal, 273 F. Supp. 3d 460, 467
|(S.D.N.Y. 2017). See also Dkt. No. 95. The Defendant is hereby ORDERED to docket
the redacted documents and corresponding exhibits by no later than December 23,
2020. SO ORDERED. (Signed by Judge Alison J. Nathan on 12/23/2020) (Inl)
(Entered: 12/23/2020)</td></tr><tr><td>12/23/2020</td><td>102</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated December 18, 2020 re: Cover Letter for Reply Memorandum for
Renewed Bail Application (Everdell, Christian) (Entered: 12/23/2020)</td></tr><tr><td>12/23/2020</td><td>103</td><td>REPLY MEMORANDUM OF LAW in Support by Ghislaine Maxwell re: Renewed
Motion for Bail. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Everdell, Christian)
(Entered: 12/23/2020)</td></tr><tr><td>12/28/2020</td><td>104</td><td>ORDER as to Ghislaine Maxwell. On December 8, 2020, Defendant Ghislaine
Maxwell filed a renewed motion for releaseon bail. Dkt No. 97. In an Opinion and
Order concurrently filed under temporary seal, the Court DENIES the Defendant's</td></tr></table>

# Case 21-58, Document 1-2, 01/12/2021, 3011673, Page 18 of 19

<table><tr><th></th><th></th><th>motion. In light of the fact that the Opinion includes potentially confidential
information that should not be filed on the public docket, the Court will permit the
parties 48 hours to propose any redactions to the Courts Opinion and Order and to
justify those redactions by reference tothe Second Circuits decision in Lugosch v.
Pyramid Co. of Onondaga, 435 F.3d 110(2d Cir. 2006). After determining which, if
any, portions of the Opinion and Order should be redacted, the Court will file the
Opinion and Order on the public docket. As a result, the Court concludes that the
Government has met its burden of persuasion that the Defendant poses a flight risk and
that pretrial detention continues to be warranted. On or before December 30, 2020, the
parties are ORDERED to submit a joint letter indicating whether they propose any
redactions and the justification for any such proposal. This resolves Dkt No. 97.
(Signed by Judge Alison J. Nathan on 12/28/20)(jw) (Entered: 12/28/2020)</th></tr><tr><td>12/30/2020</td><td>105</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated December 30, 2020
re: Joint Letter re December 28, 2020 Opinion and Order Document filed by USA.
(Comey, Maurene) (Entered: 12/30/2020)</td></tr><tr><td>12/30/2020</td><td>106</td><td>OPINION AND ORDER as to Ghislaine Maxwell. Defendant Ghislaine Maxwell has
been indicted by a grand jury on charges of conspiracy to entice minors to travel to
engage in illegal sex acts, in violation of 18 U.S.C. § 371; enticing a minor to travel to
engage in illegal sex acts, in violation of 18 U.S.C. §§ 2422 and 2; conspiracy to
transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371;
transporting minors to participate in illegal sex acts, in violation of 18 U.S.C. §§ 2423
and 2; and two charges of perjury, in violation of 18 U.S.C. § 1623. The Court held a
lengthy bail hearing on July 14, 2020. After extensive briefing and argument at the
hearing, the Court concluded that the Defendant was a clear risk of flight and that no
conditions or combination of conditions would ensure her appearance. Defendant
Ghislaine Maxwells renewed motion for release on bail, Dkt. No. 97, is DENIED.
(Signed by Judge Alison J. Nathan on 12/28/20)(jw) (Entered: 12/30/2020)</td></tr><tr><td>12/31/2020</td><td>107</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated December 31, 2020 re: Extension of Time Document filed by Ghislaine
Maxwell. (Everdell, Christian) (Entered: 12/31/2020)</td></tr><tr><td>01/05/2021</td><td>108</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell (1) on 107 LETTER MOTION
addressed to Judge Alison J. Nathan from Christian R. Everdell dated December 31,
2020 re: Extension of Time. ENDORSEMENT: SO ORDERED. (Signed by Judge
Alison J. Nathan on 1/5/2021) (ap) (Entered: 01/05/2021)</td></tr><tr><td>01/05/2021</td><td></td><td>Set/Reset Deadlines as to Ghislaine Maxwell: Motions due by 1/25/2021. Responses
| due by 2/26/2021. Replies due by 3/5/2021. (ap) (Entered: 01/05/2021)</td></tr><tr><td>01/08/2021</td><td>109</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated January 8, 2021 re: Extension of Time to File Notice of Appeal. Document filed
by Ghislaine Maxwell. (Everdell, Christian) (Entered: 01/08/2021)</td></tr><tr><td>01/11/2021</td><td>110</td><td>SEALED DOCUMENT placed in vault. (jus) (Entered: 01/11/2021)</td></tr><tr><td>01/11/2021</td><td>111</td><td>SEALED DOCUMENT placed in vault. (jus) (Entered: 01/11/2021)</td></tr><tr><td>01/11/2021</td><td>112</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell (1) denying 109 LETTER
MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell dated
January 8, 2021 re: Extension of Time to File Notice of Appeal. ENDORSEMENT:
The request is denied. Good cause for an extension of time to file a notice of appeal
has not been provided. SO ORDERED. (Signed by Judge Alison J. Nathan on
1/11/2021) (Inl) (Entered: 01/11/2021)</td></tr><tr><td>01/11/2021</td><td>113</td><td>NOTICE OF APPEAL by Ghislaine Maxwell from 104 Order. (nd) (Entered:
01/12/2021)</td></tr><tr><td>01/11/2021</td><td></td><td>Appeal Remark as to re: 113 Notice of Appeal by Ghislaine Maxwell. $505.00 Appeal
filing fee due. (nd) (Entered: 01/12/2021)</td></tr><tr><td>01/12/2021</td><td></td><td>Transmission of Notice of Appeal and Certified Copy of Docket Sheet as to Ghislaine
| Maxwell to US Court of Appeals re: 113 Notice of Appeal. (nd) (Entered: 01/12/2021)</td></tr></table>

# Case 21-58, Document 1-2, 01/12/2021, 3011673, Page 19 of 19

01/12/2021

Appeal Record Sent to USCA (Electronic File). Certified Indexed record on Appeal Electronic Files as to Ghislaine Maxwell re: 113 Notice of Appeal were transmitted to | the U.S. Court of Appeals. (nd) (Entered: 01/12/2021)

Case 120-100830-AJNеDocumenƑed 11628/28/20gePage 21 of 2

USDC SDNY

DOCUMENT
ELECTRONICALLY FILED

DOC #:
DATE FILED: 12/28/20

# UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

United States of America,

-V-

Ghislaine Maxwell,

20-CR-330 (AJN)

ORDER

Defendant.

ALISON J. NATHAN, District Judge:

On December 8, 2020, Defendant Ghislaine Maxwell filed a renewed motion for release on bail. Dkt No. 97. In an Opinion and Order concurrently filed under temporary seal, the Court DENIES the Defendant's motion.

# UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK (cont.)

In light of the fact that the Opinion includes potentially confidential information that should not be filed on the public docket, the Court will permit the parties 48 hours to propose any redactions to the Court's Opinion and Order and to justify those redactions by reference to the Second Circuit's decision in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110(2d Cir. 2006). After determining which, if any, portions of the Opinion and Order should be redacted, the Court will file the Opinion and Order on the public docket.

This Order provides the bottom line of the Court's resolution. On July 14, 2020, this Court conducted an extensive bail hearing and determined that pre-trial detention was warranted because the no conditions or set of conditions could reasonably assure the Defendant's appearance at future proceedings. Under 18 U.S.C. § 3142(f), a bail hearing may be reopened if the Court finds “that information exists that was not known to the movant at the time of the hearing and that has a material bearing on the issue whether there are conditions of release that will reasonably assure the appearance of such person as required." The Court concludes that

1

Case 120-100330-AJNеDocumen²/2001 Fed 1828/28/20gePage 22 of 2

# UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK (cont.)

none of the new information that the Defendant presented in support of her application has a material bearing on the Court's determination that she poses a flight risk.

Furthermore, for substantially the same reasons as the Court determined that detention was warranted in the initial bail hearing, the Court again concludes that no conditions of release can reasonably assure the Defendant's appearance at future proceedings. In reaching that conclusion, the Court considers the nature and circumstances of the offenses charged, the weight of the evidence against the Defendant, the history and characteristics of the Defendant, and the nature and seriousness of the danger that the Defendant's release would pose. See 18 U.S.C. § 3142(g). The Government does not contend that the Defendant poses a danger to the community. Nonetheless the Court determines that the other three factors warrant detention under 18 U.S.C. § 3142(e). The Court also finds that the Defendant's proposed bail conditions would not reasonably assure her appearance at future proceedings.

As a result, the Court concludes that the Government has met its burden of persuasion that the Defendant poses a flight risk and that pre-trial detention continues to be warranted.

# UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK (cont.)

On or before December 30, 2020, the parties are ORDERED to submit a joint letter indicating whether they propose any redactions and the justification for any such proposal.

This resolves Dkt No. 97.

SO ORDERED.

Dated: December 28, 2020
New York, New York

Alein J. Netto

ALISON J. NATHAN
United States District Judge

2

Case 21-58, Document 3-1, 01/12/2021, 3011691, Page1 of 1

# United States Court of Appeals for the Second Circuit Thurgood Marshall U.S. Courthouse 40 Foley Square New York, NY 10007

DEBRA ANN LIVINGSTON
CHIEF JUDGE

CATHERINE O'HAGAN WOLFE
CLERK OF COURT

Date: January 12, 2021 Docket #: 21-58 Short Title: United States of America v. Maxwell

DC Docket #: 1:20-cr-330-1
DC Court: SDNY (NEW YORK
CITY)
DC Judge: Nathan

# NOTICE OF RECORD ON APPEAL FILED

In the above referenced case the document indicated below has been filed in the Court.

	- Record on Appeal - Certified List

	- Record on Appeal - CD ROM

	- Record on Appeal - Paper Documents

✗ Record on Appeal - Electronic Index

	- Record on Appeal - Paper Index

Inquiries regarding this case may be directed to 212-857-8577.

Case 21-58, Document 3-2, 01/12/2021, 3011691, Page1 of 20

# NOTICE OF RECORD ON APPEAL FILED (cont.)

## CA02db Intake

From: NYSD_ECF_Pool@nysd.uscourts.gov
Sent: Tuesday, January 12, 2021 8:38 AM
To: NYSD CourtMail
Subject: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Appeal Record Sent to USCA - Electronic File

This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended.

***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.

## U.S. District Court

Southern District of New York

## Notice of Electronic Filing

The following transaction was entered on 1/12/2021 at 8:38 AM EST and filed on 1/12/2021
Case Name: USA v. Maxwell
Case Number: 1:20-cr-00330-AJN

Filer:

Document Number: No document attached

# NOTICE OF RECORD ON APPEAL FILED (cont.)

## Docket Text:

Appeal Record Sent to USCA (Electronic File). Certified Indexed record on Appeal Electronic Files as to Ghislaine Maxwell re: [113] Notice of Appeal were transmitted to the U.S. Court of Appeals. (nd)

1:20-cr-00330-AJN-1 Notice has been electronically mailed to:

Jeffrey S. Pagliuca jpagliuca@hmflaw.com, nsimmons@hmflaw.com

Laura A. Menninger Imenninger@hmflaw.com, alundberg@hmflaw.com, hrogers@hmflaw.com,
nsimmons@hmflaw.com

Bobbi C Sternheim bc@sternheimlaw.com, bcsternheim@mac.com, ecf@sternheimlaw.com

Christian R. Everdell ceverdell@cohengresser.com, autodocket@cohengresser.com

Mark Stewart Cohen mcohen@cohengresser.com, Mark-Cohen-1234@ecf.pacerpro.com,

autodocket@cohengresser.com, managingclerksoffice@cohengresser.com

Lara Elizabeth Pomerantz Lara.Pomerantz@usdoj.gov, CaseView.ECF@usdoj.gov, USANYS. ECF@USDOJ.GOV

1

# Case 21-58, Document 3-2, 01/12/2021, 3011691, Page2 of 20

Alison Gainfort Moe alison.moe@usdoj.gov, CaseView.ECF@usdoj.gov, USANYS.ECF@USDOJ.GOV

Alex Rossmiller alexander.rossmiller@usdoj.gov, CaseView.ECF@usdoj.gov, USANYS. ECF@USDOJ.GOV

Maurene Ryan Comey maurene.comey@usdoj.gov, CaseView.ECF@usdoj.gov, USANYS.ECF@USDOJ.GOV

Andrew Rohrbach Andrew.Rohrbach@usdoj.gov, caseview.ecf@usdoj.gov, usanys.ecf@usdoj.gov

1:20-cr-00330-AJN-1 Notice has been delivered by other means to:

2

Case 21-58, Document 3-2, 01/12/2021, 3011691, Page3 of 20

ECF,INTAPP

# U.S. District Court Southern District of New York (Foley Square) CRIMINAL DOCKET FOR CASE #: 1:20-cr-00330-AJN AÍI Defendants

Case title: USA v. Maxwell

Date Filed: 06/29/2020

Assigned to: Judge Alison J.
Nathan

# U.S. District Court Southern District of New York (Foley Square) CRIMINAL DOCKET FOR CASE #: 1:20-cr-00330-AJN AÍI Defendants (cont.)

## Defendant (1)

Ghislaine Maxwell
also known as
Sealed Defendant 1

represented by Christian R. Everdell
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
212-707-7268
Fax: 212-957-4514
Email: ceverdell@cohengresser.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Jeffrey S. Pagliuca
Haddon Morgan and Foreman
150 East 10th Avenue
Denver, CO 80203
(303)-831-7364
Fax: (303)-832-2628
Email: ipagliuca@hmflaw.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Disposition

Laura A. Menninger
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
(303)-831-7364
Fax: (303)-832-2628
Email: lmenninger@hmflaw.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Mark Stewart Cohen
Cohen & Gresser, LLP (NYC)
800 Third Avenue
New York, NY 10022
(212) 957-7600
Fax: (212)957-4514
Email: mcohen@cohengresser.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Bobbi C Sternheim
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
(212) 243-1100
Fax: (888) 587-4737
Email: bc@sternheimlaw.com
ATTORNEY TO BE NOTICED

Pending Counts

# Case 21-58, Document 3-2, 01/12/2021, 3011691, Page4 of 20

18:371.F CONSPIRACY TO
ENTICE MINORS TO TRAVEL
TO ENGAGE IN ILLEGAL SEX
ACTS
(1)

18:371.F CONSPIRACY TO
ENTICE MINORS TO TRAVEL
TO ENGAGE IN ILLEGAL SEX
ACTS
(1s)

18:2422.F COERCION OR
ENTICEMENT OFA MINOT TO
TRAVEL TO ENGAGE IN
ILLEGAL SEX ACTS
(2)

18:2422.F COERCION OR
ENTICEMENT OF MINOR TO
ENGAGE IN ILLEGAL SEX
ACTS
(2s)

18:371.F CONSPIRACY TO
TRANSPORT MINORS WITH
INTENT TO ENGAGE IN
CRIMINAL SEXUAL ACTIVITY
(3)

18:371.F 18:371.F CONSPIRACY
TO TRANSPORT MINORS WITH
INTENT TO ENGAGE IN
CRIMINAL SEXUAL ACTIVITY
(3s)

18:2423.F COERCION OR
ENTICEMENT OF MINOR
FEMALE (TRANSPORTATION
OF A MINOR WITH INTENT TO
ENGAGE IN CRIMINAL
SEXUAL ACTIVITY)
(4)

18:2423.F TRANSPORTATION
OF A MINOR WITH INTENT TO
ENGAGE IN CRIMINAL
SEXUAL ACTIVITY
(4s)

18:1623.F FALSE
DECLARATIONS BEFORE
GRAND JURY/COURT
(PERJURY)
(5-6)

18:1623.F FALSE
DECLARATIONS BEFORE
GRAND JURY/COURT
(5s-6s)

Highest Offense Level (Opening)
Felony

## Terminated Counts

None

Disposition

Case 21-58, Document 3-2, 01/12/2021, 3011691, Page5 of 20

Highest Offense Level
(Terminated)

None

# Case 21-58, Document 3-2, 01/12/2021, 3011691, Page4 of 20 (cont.)

## Terminated Counts (cont.)

<table><tr><th>Complaints</th><th>Disposition</th><th></th></tr><tr><td>None</td><td></td><td></td></tr><tr><td>Plaintiff</td><td></td><td></td></tr><tr><td>USA</td><td>represented by</td><td>Alex Rossmiller
U.S. Attorney's Office, Southern District of
New York
1 St. Andrew's Plaza
New York, NY 10007
(212) 637-2415
Email: alexander.rossmiller@usdoj.gov
LEAD ATTORNEY
PRO HAC VICE
ATTORNEY TO BE NOTICED
Designation: Assistant US Attorney</td></tr><tr><td></td><td></td><td>Alison Gainfort Moe
United States Attorney's Office, SDNY
One Saint Andrew's Plaza
New York, NY 10007
(212) 637-2225
Email: alison.moe@usdoj.gov
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Designation: Assistant US Attorney</td></tr><tr><td></td><td></td><td>Maurene Ryan Comey
United States Attorney's Office, SDNY
One Saint Andrew's Plaza
New York, NY 10007
(212) 637-2324
Email: maurene.comey@usdoj.gov
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Designation: Assistant US Attorney

Andrew Rohrbach
DOJ-USAO
1 St. Andrew's Plaza
New York, NY 10007
212-637-2345
Email: Andrew.Rohrbach@usdoj.gov
ATTORNEY TO BE NOTICED

Lara Elizabeth Pomerantz
United States Attorney's Office
One St. Andrew's Plaza
New York, NY 10007
212-637-2343
Fax: 212-637-2527
Email: Lara.Pomerantz@usdoj.gov
ATTORNEY TO BE NOTICED</td></tr></table>

# Case 21-58, Document 3-2, 01/12/2021, 3011691, Page4 of 20 (cont.)

## Terminated Counts (cont.)

Date Filed

# Docket Text

# Case 21-58, Document 3-2, 01/12/2021, 3011691, Page6 of 20

<table><tr><th>06/29/2020</th><th>1</th><th>SEALED INDICTMENT as to Sealed Defendant 1 (1) count(s) 1, 2, 3, 4, 5-6. (jm)
(Main Document 1 replaced on 7/2/2020) (jm). (Entered: 07/02/2020)</th></tr><tr><td>07/02/2020</td><td>2</td><td>Order to Unseal Indictment as to Sealed Defendant 1. (Signed by Magistrate Judge
| Katharine H. Parker on 7/2/20)(jm) (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td></td><td>| INDICTMENT UNSEALED as to Ghislaine Maxwell. (jm) (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td></td><td>Case Designated ECF as to Ghislaine Maxwell. (jm) (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td></td><td>Case as to Ghislaine Maxwell ASSIGNED to Judge Alison J. Nathan. (jm) (Entered:
07/02/2020)</td></tr><tr><td>07/02/2020</td><td></td><td>Attorney update in case as to Ghislaine Maxwell. Attorney Alex Rossmiller, Maurene
Ryan Comey,Alison Gainfort Moe for USA added. (jm) (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td>4</td><td>MOTION to detain defendant. Document filed by USA as to Ghislaine Maxwell.
(Moe, Alison) (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td></td><td>Arrest of Ghislaine Maxwell in the United States District Court - District of New
Hampshire. (jm) (Entered: 07/06/2020)</td></tr><tr><td>07/05/2020</td><td>5</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Alex Rossmiller dated July 5, 2020 re:
Request to Schedule Initial Appearance Document filed by USA. (Comey, Maurene)
(Entered: 07/05/2020)</td></tr><tr><td>07/06/2020</td><td>6</td><td>Rule 5(c)(3) Documents Received as to Ghislaine Maxwell from the United States
District Court District of New Hampshire. (jm) (Entered: 07/06/2020)</td></tr><tr><td>07/06/2020</td><td>7</td><td>ORDER as to Ghislaine Maxwell. This matter has been assigned to me for all
purposes. In its July 5, 2020 letter, the Government on behalf of the parties requested
that the Court schedule an arraignment, initial appearance, and bail hearing in this
matter in the afternoon of Friday, July 10. See Dkt. No. 5. In light of the COVID
public health crisis, there are significant safety issues related to in-court proceedings.
If the Defendant is willing to waive her physical presence, this proceeding will be
conducted remotely. To that end, defense counsel should confer with the Defendant
regarding waiving her physical presence. If the Defendant wishes to waive her
physical presence for this proceeding, she and her counsel should sign the attached
form in advance of the proceeding if feasible. If this proceeding is to be conducted
remotely, there are protocols at the Metropolitan Detention Center that limit the times
at which the Defendant could be produced so that she could appear by video. In the
next week, the Defendant could be produced by video at either 9:00 a.m. on July 9,
2020 or sometime during the morning of July 14, 2020. Counsel are hereby ordered to
meet and confer regarding scheduling for this initial proceeding in light of these
constraints. If counsel does anticipate proceeding remotely, by 9:00 p.m. tonight,
counsel should file a joint letter proposing a date and time for the proceeding
consistent with this scheduling information, as well as a revised briefing schedule for
the Defendant's bail application.SO ORDERED. (Signed by Judge Alison J. Nathan on
7/6/2020)(jbo) (Entered: 07/06/2020)</td></tr><tr><td>07/06/2020</td><td>8</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Mark S.
Cohen dated July 6, 2020 re: Scheduling (Cohen, Mark) (Entered: 07/06/2020)</td></tr><tr><td>07/07/2020</td><td>2</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
Alex Rossmiller dated July 7, 2020 re: scheduling Document filed by USA.
(Rossmiller, Alex) (Entered: 07/07/2020)</td></tr><tr><td>07/07/2020</td><td>10</td><td>ORDER as to Ghislaine Maxwell. An arraignment, initial conference, and bail hearing
in this matter is hereby scheduled to occur as a remote video/teleconference using an
internet platform on July 14, 2020 at 1 p.m. In advance of the conference, Chambers
will email counsel with further information on how to access the video conference. To
optimize the quality of the video feed, only the Court, the Defendant, defense counsel,
and counsel for the Government will appear by video for the proceeding; all others
may access the audio of the public proceeding by telephone. Due to the limited
capacity of the internet platform system, only one attorney per party may participate
by video. Co-counsel, members of the press, and the public may access the audio feed
of the proceeding by calling a dial-in number, which the Court will provide in</td></tr></table>

# Case 21-58, Document 3-2, 01/12/2021, 3011691, Page7 of 20

<table><tr><th></th><th></th><th>advance of the proceeding by subsequent order. Given the high degree of public
interest in this case, a video feed of the remote proceeding will be available for
viewing in the Jury Assembly Room located at the Daniel Patrick Moynihan
Courthouse, 500 Pearl Street, New York, NY. Due to social distancing requirements,
| seating will be extremely limited; when capacity is reached no additional persons will
be admitted. Per the S.D.N.Y. COVID-19 Courthouse Entry Program, anyone who
appears at any S.D.N.Y. courthouse must complete a questionnaire on the date of the
proceeding prior to arriving at the courthouse. All visitors must also have their
temperature taken when they arrive at the courthouse. Please see the instructions,
attached. Completing the questionnaire ahead of time will save time and effort upon
entry. Only persons who meet the entry requirements established by the questionnaire
and whose temperatures are below 100.4 degrees will be allowed to enter the
courthouse. Face coverings that cover the nose and mouth must be worn at all times.
Anyone who fails to comply with the COVID-19 protocols that have been adopted by
the Court will be required to leave the courthouse. There are no exceptions. As
discussed in the Court's previous order, defense counsel shall, if possible, discuss the
Waiver of Right to be Present at Criminal Proceeding with the Defendant prior to the
proceeding. See Dkt. No. 7. If the Defendant consents, and is able to sign the form
(either personally or, in accordance with Standing Order 20-MC-174 of March 27,
2020, by defense counsel), defense counsel shall file the executed form at least 24
hours prior to the proceeding. In the event the Defendant consents, but counsel is
unable to obtain or affix the Defendant's signature on the form, the Court will conduct
an inquiry at the outset of the proceeding to determine whether it is appropriate for the
Court to add the Defendant's signature to the form. Pursuant to 18 U.S.C. § 3771(c)(1),
the Government must make their best efforts to see that crime victims are notified of,
and accorded, the rights provided to them in that section. This includes [t]he right to
reasonable, accurate, and timely notice of any public court proceeding... involving the
crime or of any release... of the accused and "[t]he right to be reasonably heard at any
public proceeding in the district court involving release." Id. § 3771(a)(2), (4). The
Court will inquire with the Government as to the extent of those efforts. So that
appropriate logistical arrangements can be made, the Government shall inform the
Court by email within 24 hours in advance of the proceeding if any alleged victim
wishes to be heard on the question of detention pending trial. Finally, the time between
the Defendant's arrest and July 6, 2020 is excluded under the Speedy Trial Act due to
the delay involved in transferring the Defendant from another district. See 18 U.S.C. §
3161(h)(1)(F). And the Court further excludes time under the Speedy Trial Act from
today through July 14, 2020. Due to the logistical issues involved in conducting a
remote proceeding, the Court finds "that the ends of justice served by [this exclusion]
outweigh the best interest of the public and the defendant in a speedy trial." 18 U.S.C.
§ 3161(h)(7)(A). The exclusion is also supported by the need for the parties to discuss
a potential protective order, which will facilitate the timely production of discovery in
a manner protective of the rights of third parties. See Dkt. No. 5. SO ORDERED.
(Signed by Judge Alison J. Nathan on 7/7/2020)(jbo) (Entered: 07/07/2020)</th></tr><tr><td>07/08/2020</td><td>11</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on 2 LETTER by USA as to
Ghislaine Maxwell addressed to Judge Alison J. Nathan from Alex Rossmiller dated
July 7, 2020 re: scheduling. ENDORSEMENT: The Court hereby sets the following
briefing schedule. The Defense response is due by 1:00 p.m. on July 10, 2020. The
Government reply is due by 1:00 p.m. on July 13, 2020. Additionally, defense counsel
is ordered to file notices of appearance on the docket by the end of the day today. SO
ORDERED. (Responses due by 7/10/2020. Replies due by 7/13/2020.) (Signed by
Judge Alison J. Nathan on 7/8/2020) (Inl) (Entered: 07/08/2020)</td></tr><tr><td>07/08/2020</td><td>12</td><td>NOTICE OF ATTORNEY APPEARANCE: Mark Stewart Cohen appearing for
| Ghislaine Maxwell. Appearance Type: Retained. (Cohen, Mark) (Entered: 07/08/2020)</td></tr><tr><td>07/08/2020</td><td>13</td><td>NOTICE OF ATTORNEY APPEARANCE: Christian R. Everdell appearing for
Ghislaine Maxwell. Appearance Type: Retained. (Everdell, Christian) (Entered:
07/08/2020)</td></tr><tr><td>07/08/2020</td><td>14</td><td>NOTICE OF ATTORNEY APPEARANCE: Laura A. Menninger appearing for
Ghislaine Maxwell. Appearance Type: Retained. (Menninger, Laura) (Entered:
07/08/2020)</td></tr></table>

# Case 21-58, Document 3-2, 01/12/2021, 3011691, Page8 of 20

<table><tr><th>07/08/2020</th><th>15</th><th>MOTION for Jeffrey S. Pagliuca to Appear Pro Hac Vice. Filing fee $ 200.00, receipt
number ANYSDC-20605229. Motion and supporting papers to be reviewed by
Clerk's Office staff. Document filed by Ghislaine Maxwell. (Attachments: # 1 Exhibit
Declaration of Jeffrey S. Pagliuca, # 2 Exhibit Certificate of Good Standing, # 3 Text
of Proposed Order Proposed Order)(Pagliuca, Jeffrey) (Entered: 07/08/2020)</th></tr><tr><td>07/08/2020</td><td>17</td><td>(S1) SUPERSEDING INDICTMENT FILED as to Ghislaine Maxwell (1) count(s) 1s,
2s, 3s, 4s, 5s-6s. (jm) (Entered: 07/10/2020)</td></tr><tr><td>07/09/2020</td><td></td><td>&gt;&gt;&gt;NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document
No. 15 MOTION for Jeffrey S. Pagliuca to Appear Pro Hac Vice. Filing fee $
200.00, receipt number ANYSDC-20605229. Motion and supporting papers to be
reviewed by Clerk's Office staff. The document has been reviewed and there are
no deficiencies. (aea) (Entered: 07/09/2020)</td></tr><tr><td>07/09/2020</td><td>16</td><td>ORDER as to Ghislaine Maxwell. As discussed in its previous order, the Court will
hold an arraignment, initial conference, and bail hearing in this matter remotely as a
video/teleconference on July 14, 2020 at 1 pm. Members of the press and the public in
the United States may access the live audio feed of the proceeding by calling
855-268-7844 and using access code 32091812# and PIN 9921299#. Those outside of
the United States may access the live audio feed by calling 214-416-0400 and using
the same access code and PIN. These phone lines can accommodate approximately
500 callers on a first come, first serve basis. The Court will provide counsel for both
sides an additional dial-in number to be used to ensure audio access to the proceeding
for non-speaking co-counsel, alleged victims, and any family members of the
Defendant. The United States Attorney's Office should email Chambers with
information regarding any alleged victims who are entitled, pursuant to 18 U.S.C.
$3771(a)(4), to be heard at the bail hearing and who wish to be heard. The Court will
then provide information as to the logistics for their dial-in access. As the Court
described in a previous order, members of the press and public may watch and listen to
the live video feed in the Jury Assembly Room, at the Daniel Patrick Moynihan
Courthouse, 500 Pearl Street. See Dkt. No. 10. However, in light of COVID-19,
seating will be limited to approximately 60 seats in order to enable appropriate social
| distancing and ensure public safety. Counsel for the Defendant and the Government
| may contact Chambers by email if there is a request to accommodate alleged victims
| or family members of the Defendant. Members of the credentialed in-house press
corps may contact the District Executive's Office about seating. Otherwise, all seating
will be allocated on a first come, first serve basis and in accordance with the S.D.N.Y.
|COVID-19 Courthouse Entry Program and this Court's previous order of July 7, 2020.
See Dkt. No. 10. If conditions change or the Court otherwise concludes that allowing
for in-person viewing of the video feed at the courthouse is not consistent with public
health, the Court may provide audio access by telephone only. Any photographing,
recording, or rebroadcasting of federal court proceedings is prohibited by law.
Violation of these prohibitions may result in fines or sanctions, including removal of
| court issued media credentials, restricted entry to future hearings, denial of entry to
future hearings, or any other sanctions deemed necessary by the Court. SO
ORDERED. (Signed by Judge Alison J. Nathan on 7/9/2020)(jbo) (Entered:
07/09/2020)</td></tr><tr><td>07/10/2020</td><td>18</td><td>MEMORANDUM in Opposition by Ghislaine Maxwell re 4 MOTION to detain
defendant.. (Cohen, Mark) (Entered: 07/10/2020)</td></tr><tr><td>07/10/2020</td><td>19</td><td>NOTICE OF ATTORNEY APPEARANCE: Mark Stewart Cohen appearing for
Ghislaine Maxwell. Appearance Type: Retained. (Cohen, Mark) (Entered: 07/10/2020)</td></tr><tr><td>07/10/2020</td><td>20</td><td>NOTICE OF ATTORNEY APPEARANCE: Christian R. Everdell appearing for
Ghislaine Maxwell. Appearance Type: Retained. (Everdell, Christian) (Entered:
07/10/2020)</td></tr><tr><td>07/10/2020</td><td>21</td><td>WAIVER of Personal Appearance at Arraignment and Entry of Plea of Not Guilty by
Ghislaine Maxwell. (Everdell, Christian) (Entered: 07/10/2020)</td></tr><tr><td>07/13/2020</td><td>22</td><td>REPLY MEMORANDUM OF LAW in Support by USA as to Ghislaine Maxwell re:
4 MOTION to detain defendant. . (Moe, Alison) (Entered: 07/13/2020)</td></tr><tr><td>07/13/2020</td><td></td><td>ORDER granting 15 Motion for Jeffrey Pagliuca to Appear Pro Hac Vice as to
Ghislaine Maxwell (1). (Signed by Judge Alison J. Nathan on 7/13/2020) (kwi)</td></tr></table>

# Case 21-58, Document 3-2, 01/12/2021, 3011691, Page9 of 20

<table><tr><th></th><th></th><th>(Entered: 07/13/2020)</th></tr><tr><td>07/14/2020</td><td>23</td><td>ORDER as to Ghislaine Maxwell. For the reasons stated on the record at today's
proceeding, the Governments motion to detain the Defendant pending trial is hereby
GRANTED (Signed by Judge Alison J. Nathan on 7/14/20)(jw) (Entered: 07/14/2020)</td></tr><tr><td>07/14/2020</td><td></td><td>Minute Entry for proceedings held before Judge Alison J. Nathan: Arraignment as to
Ghislaine Maxwell (1) Count 1s,2s,3s, 4s, 5s-6s held on 7/14/2020. Defendant
Ghislaine Maxwell present by video conference with attorney Mark Cohen present by
video conference, AUSA Alison Moe, Alex Rossmiller and Maurene Comey for the
government present by video conference, Pretrial Service Officer Lea Harmon present
by telephone and Court Reporter Kristine Caraannante. Defendant enters a plea of Not
Guilty to the S1 indictment. Trial set for July 12, 2021. See Order. Time is excluded
under the Speedy Trial Act from today until July 12, 2021. Bail is denied. Defendant is
| remanded. See Transcript. (jw) (Entered: 07/14/2020)</td></tr><tr><td>07/14/2020</td><td></td><td>Minute Entry for proceedings held before Judge Alison J. Nathan: Plea entered by
Ghislaine Maxwell (1) Count 1s,2s,3s, 4s, 5s-6s Not Guilty. (jw) (Entered: 07/14/2020)</td></tr><tr><td>07/14/2020</td><td>24</td><td>Waiver of Right to be Present at Criminal Proceeding as to Ghislaine Maxwell re:
Arraignment, Bail Hearing, Conference. (jw) (Entered: 07/14/2020)</td></tr><tr><td>07/15/2020</td><td>25</td><td>ORDER as to Ghislaine Maxwell. Initial non-electronic discovery, generally to
include search warrant applications and subpoena returns, is due by Friday, August 21,
2020. Completion of discovery, to include electronic materials, is due by Monday,
November 9, 2020. Motions are due by Monday, December 21, 2020. Motion
responses are due by Friday, January 22, 2021. Motion replies are due by Friday,
February 5, 2021. Trial is set for Monday, July 12, 2021 (Discovery due by
8/21/2020., Motions due by 12/21/2020) (Signed by Judge Alison J. Nathan on
7/15/20)(jw) (Entered: 07/15/2020)</td></tr><tr><td>07/21/2020</td><td>26</td><td>ORDER as to Ghislaine Maxwell: The Court has received a significant number of
letters and messages from non-parties that purport to be related to this case. These
submissions are either procedurally improper or irrelevant to the judicial function.
Therefore, they will not be considered or docketed. The Court will accord the same
treatment to any similar correspondence it receives in the future. SO ORDERED.
(Signed by Judge Alison J. Nathan on 7/21/2020) (Inl) (Entered: 07/21/2020)</td></tr><tr><td>07/21/2020</td><td>27</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Jeffrey S. Pagliuca
dated July 21, 2020 re: Local Criminal Rule 23.1. Document filed by Ghislaine
Maxwell. (Pagliuca, Jeffrey) (Entered: 07/21/2020)</td></tr><tr><td>07/23/2020</td><td>28</td><td>ORDER as to Ghislaine Maxwell: The Defense has moved for an order "prohibiting
the Government, its agents and counsel for witnesses from making extrajudicial
statements concerning this case." Dkt. No. 27 at 1. The Court firmly expects that
counsel for all involved parties will exercise great care to ensure compliance with this
Court's local rules, including Local Criminal Rule 23.1, and the rules of professional
responsibility. In light of this clear expectation, the Court does not believe that further
action is needed at this time to protect the Defendant's right to a fair trial by an
impartial jury. Accordingly, it denies the Defendant's motion without prejudice. But
the Court warns counsel and agents for the parties and counsel for potential witnesses
that going forward it will not hesitate to take appropriate action in the face of
violations of any relevant rules. The Court will ensure strict compliance with those
rules and will ensure that the Defendant's right to a fair trial will be safeguarded.
(Signed by Judge Alison J. Nathan on 7/23/2020) (ap) (Entered: 07/23/2020)</td></tr><tr><td>07/27/2020</td><td>29</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated July 27, 2020 re: Proposed Protective Order. Document filed by Ghislaine
Maxwell. (Attachments: # 1 Exhibit A (Proposed Protective Order))(Everdell,
Christian) (Entered: 07/27/2020)</td></tr><tr><td>07/27/2020</td><td>30</td><td>AFFIDAVIT of Christian R. Everdell by Ghislaine Maxwell. (Everdell, Christian)
(Entered: 07/27/2020)</td></tr><tr><td>07/27/2020</td><td>31</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
Alison Moe dated July 27, 2020 re: requesting until 5 p.m. tomorrow to respond to
defense counsel's letter, filed July 27, 2020 Document filed by USA. (Moe, Alison)</td></tr></table>

# Case 21-58, Document 3-2, 01/12/2021, 3011691, Page 10 of 20

<table><tr><th></th><th></th><th>(Entered: 07/27/2020)</th></tr><tr><td>07/27/2020</td><td>32</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on 31 LETTER by USA as to
Ghislaine Maxwell addressed to Judge Alison J. Nathan from Alison Moe dated July
27, 2020 re: requesting until 5 p.m. tomorrow to respond to defense counsel's letter,
filed July 27, 2020. ENDORSEMENT: The Government's response to the Defense's
letter is due by 5 p.m. on July 28, 2020. The Defense may file a reply by 5 p.m. on
July 29, 2020. Before the Government's response is filed, the parties must meet and
confer by phone regarding this issue, and any response from the Government must
contain an affirmation that the parties have done so. SO ORDERED. (Responses due
by 7/28/2020. Replies due by 7/29/2020.) (Signed by Judge Alison J. Nathan on
7/27/2020) (Inl) (Entered: 07/27/2020)</td></tr><tr><td>07/28/2020</td><td>33</td><td>LETTER RESPONSE to Motion by USA as to Ghislaine Maxwell addressed to Judge
Alison J. Nathan from Alex Rossmiller dated July 28, 2020 re: 29 LETTER MOTION
addressed to Judge Alison J. Nathan from Christian R. Everdell dated July 27, 2020 re:
Proposed Protective Order .. (Attachments: #1 Exhibit A (proposed protective
order))(Rossmiller, Alex) (Entered: 07/28/2020)</td></tr><tr><td>07/28/2020</td><td>34</td><td>AFFIDAVIT of Alex Rossmiller by USA as to Ghislaine Maxwell. (Rossmiller, Alex)
(Entered: 07/28/2020)</td></tr><tr><td>07/29/2020</td><td>35</td><td>LETTER REPLY TO RESPONSE to Motion by Ghislaine Maxwell addressed to
Judge Alison J. Nathan from Christian R. Everdell dated July 29, 2020 re 29 LETTER
MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell dated July
27, 2020 re: Proposed Protective Order .. (Everdell, Christian) (Entered: 07/29/2020)</td></tr><tr><td>07/30/2020</td><td>36</td><td>PROTECTIVE ORDER as to Ghislaine Maxwell...regarding procedures to be
followed that shall govern the handling of confidential material. SO ORDERED:
(Signed by Judge Alison J. Nathan on 7/30/2020)(bw) (Entered: 07/31/2020)</td></tr><tr><td>07/30/2020</td><td>37</td><td>MEMORANDUM OPINION &amp; ORDER as to Ghislaine Maxwell. Both parties have
asked for the Court to enter a protective order. While they agree on most of the
language, two areas of dispute have emerged. First, Ms. Maxwell seeks language
allowing her to publicly reference alleged victims or witnesses who have spoken on
the public record to the media or in public fora, or in litigation relating to Ms. Maxwell
or Jeffrey Epstein. Second, Ms. Maxwell seeks language restricting potential
Government witnesses and their counsel from using discovery materials for any
purpose other than preparing for the criminal trial in this action. The Government has
proposed contrary language on both of these issues. For the following reasons, the
Court adopts the Government's proposed protective order Under Federal Rule of
Criminal Procedure 16(d)(1), "[a]t any time the court may, for good cause, deny,
restrict, or defer discovery or inspection, or grant other appropriate relief." The good
cause standard "requires courts to balance several interests, including whether
| dissemination of the discovery materials inflicts hazard to others... whether the
imposition of the protective order would prejudice the defendant," and "the public's
interest in the information." United States v. Smith, 985 F. Supp. 2d 506, 522
|(S.D.N.Y. 2013). The party seeking to restrict disclosure bears the burden of showing
good cause. Cf. Gambale v. Deutsche Bank AG, 377 F.3d 133, 142 (2d Cir. 2004).
| First, the Court finds that the Government has met its burden of showing good cause
with regard to restricting the ability of Ms. Maxwell to publicly reference alleged
victims and witnesses other than those who have publicly identified themselves in this
litigation. As a general matter, it is undisputed that there is a strong and specific
interest in protecting the privacy of alleged victims and witnesses in this case that
supports restricting the disclosure of their identities. Dkt. No. 29 at 3 (acknowledging
that as a baseline the protective order should "prohibit[] Ms. Maxwell, defense
counsel, and others on the defense team from disclosing or disseminating the identity
of any alleged victim or potential witness referenced in the discovery materials"); see
also United States v. Corley, No. 13-cr-48, 2016 U.S. Dist. LEXIS 194426, at *11
(S.D.N.Y. Jan. 15, 2016). The Defense argues this interest is significantly diminished
for individuals who have spoken on the public record about Ms. Maxwell or Jeffrey
Epstein, because they have voluntarily chosen to identify themselves. But not all
accusations or public statements are equal. Deciding to participate in or contribute to a
criminal investigation or prosecution is a far different matter than simply making a
public statement "relating to" Ms. Maxwell or Jeffrey Epstein, particularly since such a
statement might have occurred decades ago and have no relevance to the charges in</td></tr></table>

# Case 21-58, Document 3-2, 01/12/2021, 3011691, Page11 of 20

<table><tr><th></th><th></th><th>this case. These individuals still maintain a significant privacy interest that must be
safeguarded. The exception the Defense seeks is too broad and risks undermining the
protections of the privacy of witnesses and alleged victims that is required by law. In
contrast, the Government's proffered language would allow Ms. Maxwell to publicly
reference individuals who have spoken by name on the record in this case. It also
allows the Defense to "referenc[e] the identities of individuals they believe may be
relevant... to Potential Defense Witnesses and their counsel during the course of the
investigation and preparation of the defense case at trial." Dkt. No. 33-1, 5. This
proposal adequately balances the interests at stake. And as the Government's letter
notes, see Dkt. No. 33 at 4, to the extent that the Defense needs an exception to the
protective order for a specific investigative purpose, they can make applications to the
Court on a case-by-case basis. Second, restrictions on the ability of potential
witnesses and their counsel to use discovery materials for purposes other than
preparing for trial in this case are unwarranted. The request appears unprecedented
despite the fact that there have been many high-profile criminal matters that had
related civil litigation. The Government labors under many restrictions including Rule
6(e) of the Federal Rules of Criminal Procedure, the Privacy Act of 1974, and other
policies of the Department of Justice and the U.S. Attorney's Office for the Southern
District of New York, all of which the Court expects the Government to scrupulously
follow. Furthermore, the Government indicates that it will likely only provide potential
witnesses with materials that those witnesses already have in their possession. See Dkt.
No. 33 at 6. And of course, those witnesses who do testify at trial would be subject to
examination on the record as to what materials were provided or shown to them by the
Government. Nothing in the Defense's papers explains how its unprecedented
proposed restriction is somehow necessary to ensure a fair trial. For the foregoing
reasons, the Court adopts the Government's proposed protective order, which will be
entered on the docket. This resolves Dkt. No. 29. SO ORDERED. (Signed by Judge
Alison J. Nathan on 7/30/2020)(bw) (Entered: 07/31/2020)</th></tr><tr><td>08/10/2020</td><td>38</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated August 10, 2020 re: Discovery Disclosure and Access. Document filed by
Ghislaine Maxwell. (Everdell, Christian) (Entered: 08/10/2020)</td></tr><tr><td>08/10/2020</td><td>39</td><td>AFFIDAVIT of Christian R. Everdell by Ghislaine Maxwell. (Everdell, Christian)
(Entered: 08/10/2020)</td></tr><tr><td>08/11/2020</td><td>40</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 38 LETTER MOTION
addressed to Judge Alison J. Nathan from Christian R. Everdell dated August 10, 2020
re: Discovery Disclosure and Access. ENDORSEMENT: The Government is hereby
| ORDERED to respond to the Defendant's letter motion by Thursday, August 13, 2020.
The Defendant's reply, if any, is due on or before Monday, August 17, 2020.
(Responses due by 8/13/2020. Replies due by 8/17/2020) (Signed by Judge Alison J.
Nathan on 8/11/2020) (ap) (Entered: 08/11/2020)</td></tr><tr><td>08/13/2020</td><td>41</td><td>LETTER RESPONSE in Opposition by USA as to Ghislaine Maxwell addressed to
Judge Alison J. Nathan from Alex Rossmiller dated August 13, 2020 re: 38 LETTER
MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell dated
August 10, 2020 re: Discovery Disclosure and Access .. (Rossmiller, Alex) (Entered:
08/13/2020)</td></tr><tr><td>08/17/2020</td><td>42</td><td>LETTER REPLY TO RESPONSE to Motion by Ghislaine Maxwell addressed to
Judge Alison J. Nathan from Christian R. Everdell dated August 17, 2020 re 38
LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated August 10, 2020 re: Discovery Disclosure and Access .. (Everdell, Christian)
(Entered: 08/17/2020)</td></tr><tr><td>08/17/2020</td><td>43</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Jeffrey S. Pagliuca
dated August 17, 2020 re: Request for Permission to Submit Letter Motion in Excess
of Three Pages. Document filed by Ghislaine Maxwell. (Pagliuca, Jeffrey) (Entered:
08/17/2020)</td></tr><tr><td>08/18/2020</td><td>44</td><td>ORDER as to Ghislaine Maxwell: On August 17, 2020, the Defendant filed a letter
motion seeking a modification of this Court's Protective Order, which the Court
entered on July 30, 2020. Defendant also moves to file that letter motion under seal.
The Governments opposition to Defendant's letter motion is hereby due Friday, August
21 at 12 p.m. The Defendant's reply is due on Monday, August 24 at 12 p.m. The</td></tr></table>

# Case 21-58, Document 3-2, 01/12/2021, 3011691, Page 12 of 20

<table><tr><th></th><th></th><th>parties shall propose redactions to the letter briefing on this issue. Alternatively, the
parties shall provide support and argument for why the letter motions should be sealed
in their entirety. SO ORDERED. (Responses due by 8/21/2020. Replies due by
8/24/2020.) (Signed by Judge Alison J. Nathan on 8/18/2020) (Inl) (Entered:
08/18/2020)</th></tr><tr><td>08/20/2020</td><td>45</td><td>NOTICE OF ATTORNEY APPEARANCE Lara Elizabeth Pomerantz appearing for
USA. (Pomerantz, Lara) (Entered: 08/20/2020)</td></tr><tr><td>08/20/2020</td><td>50</td><td>SEALED DOCUMENT placed in vault. (mhe) (Entered: 08/27/2020)</td></tr><tr><td>08/21/2020</td><td>46</td><td>LETTER RESPONSE in Opposition by USA as to Ghislaine Maxwell addressed to
Judge Alison J. Nathan from Maurene Comey dated August 21, 2020 re: 43 LETTER
MOTION addressed to Judge Alison J. Nathan from Jeffrey S. Pagliuca dated August
17, 2020 re: Request for Permission to Submit Letter Motion in Excess of Three Pages
.. (Rossmiller, Alex) (Entered: 08/21/2020)</td></tr><tr><td>08/21/2020</td><td>47</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
Maurene Comey dated August 21, 2020 re: Proposed redactions to letter briefing, in
response to the Court's Order of August 18, 2020 Document filed by USA.
(Rossmiller, Alex) (Entered: 08/21/2020)</td></tr><tr><td>08/24/2020</td><td>48</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Laura A. Menninger
dated August 24, 2020 re: Request to File Under Seal: Proposed Redactions to Request
to Modify Protective Order and Reply in Support Thereof. Document filed by
Ghislaine Maxwell. (Menninger, Laura) (Entered: 08/24/2020)</td></tr><tr><td>08/25/2020</td><td>49</td><td>MEMORANDUM OPINION AND ORDER: denying without prejudice 38 LETTER
MOTION as to Ghislaine Maxwell (1). On August 10, 2020, the Defendant filed a
letter motion related to two issues. Dkt. No. 38. First, the Defendant seeks an order
directing the Government to disclose to defense counsel immediately the identities of
the three alleged victims referenced in the indictment. Second, the Defendant seeks an
order directing the Bureau of Prisons ("BOP") to release the Defendant into the general
population and to provide her with increased access to the discovery materials. For the
reasons that follow, Defendant's requests are DENIED without prejudice.... [See this
Memorandum Opinion And Order]... III. Conclusion: For the reasons stated above,
Defendant's requests contained in Dkt. No. 38 are DENIED without prejudice.
Following the close of discovery, the parties shall meet and confer on an appropriate
schedule for pre-trial disclosures, including the disclosure of § 3500 material, exhibit
lists, and witness lists, taking into account all relevant factors. The Government is
hereby ORDERED to submit written status updates every 90 days detailing any
material changes to the conditions of Ms. Maxwell's confinement, with particular
emphasis on her access to legal materials and ability to communicate with defense
counsel. SO ORDERED. (Signed by Judge Alison J. Nathan on 8/25/2020) (bw)
(Entered: 08/25/2020)</td></tr><tr><td>09/02/2020</td><td>51</td><td>MEMORANDUMOPINION AND ORDER as to Ghislaine Maxwell: On August 17,
2020, Defendant Ghislaine Maxwell filed a sealed letter motion seeking an Order
modifying the protective order in this case. Specifically, she sought a Court order
allowing her to file under seal in certain civil cases ("Civil Cases") materials
("Documents") that she received in discovery from the Government in this case. She
also sought permission to reference, but not file, other discovery material that the
Government produced in this case. For the reasons that follow, Defendant's requests
are DENIED. SO ORDERED. (Signed by Judge Alison J. Nathan on 9/2/2020)(See
MEMORANDUM OPINION AND ORDER as set forth) (Inl) (Entered: 09/02/2020)</td></tr><tr><td>09/02/2020</td><td>52</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan, from Jeffrey S.
Pagliuca dated 8/17/2020 re: Defense counsel writes with redacted request to modify
protective order. (ap) (Entered: 09/02/2020)</td></tr><tr><td>09/04/2020</td><td>55</td><td>NOTICE OF APPEAL by Ghislaine Maxwell from 51 Memorandum &amp; Opinion.
Filing fee $ 505.00, receipt number 465401266036. (tp) (Entered: 09/09/2020)</td></tr><tr><td>09/08/2020</td><td>53</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan dated 8/24/2020
re: Proposed Redactions to Request to Modify Protective Order. (jbo) (Entered:
09/08/2020)</td></tr></table>

# Case 21-58, Document 3-2, 01/12/2021, 3011691, Page13 of 20

<table><tr><th>09/08/2020</th><th>54</th><th>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan dated 8/24/2020
re: Reply in Support of Request to Modify Protective Order. (jbo) (Entered:
09/08/2020)</th></tr><tr><td>09/09/2020</td><td>|</td><td>Transmission of Notice of Appeal and Certified Copy of Docket Sheet as to Ghislaine
Maxwell to US Court of Appeals re: 55 Notice of Appeal. (tp) (Entered: 09/09/2020)</td></tr><tr><td>09/09/2020</td><td></td><td>Appeal Record Sent to USCA (Electronic File). Certified Indexed record on Appeal
Electronic Files as to Ghislaine Maxwell re: 55 Notice of Appeal were transmitted to
the U.S. Court of Appeals. (tp) (Entered: 09/09/2020)</td></tr><tr><td>09/10/2020</td><td>56</td><td>SEALED DOCUMENT placed in vault. (dn) (Entered: 09/11/2020)</td></tr><tr><td>09/10/2020</td><td>57</td><td>SEALED DOCUMENT placed in vault. (dn) (Entered: 09/11/2020)</td></tr><tr><td>09/24/2020</td><td>58</td><td>SEALED DOCUMENT placed in vault. (mhe) (Entered: 09/24/2020)</td></tr><tr><td>10/05/2020</td><td>59</td><td>NOTICE OF ATTORNEY APPEARANCE: Bobbi C Sternheim appearing for
Ghislaine Maxwell. Appearance Type: Retained. (Sternheim, Bobbi) (Entered:
10/05/2020)</td></tr><tr><td>10/06/2020</td><td>60</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated October 6, 2020 re:
Request to Delay Disclosure Document filed by USA. (Comey, Maurene) (Entered:
10/06/2020)</td></tr><tr><td>10/06/2020</td><td>61</td><td>AFFIDAVIT of Maurene Comey by USA as to Ghislaine Maxwell. (Comey, Maurene)
(Entered: 10/06/2020)</td></tr><tr><td>10/07/2020</td><td>62</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 60 Accordingly, the
Government respectfully requests that the Court approve the Government's request to
delay disclosure of these Materials...ENDORSEMENT...The Defendant shall file any
opposition to the Government's request by October 14, 2020. The Government's reply,
if any, is due by October 20, 2020. SO ORDERED. (Government Replies due by
10/20/2020., Defendant Responses due by 10/14/2020) (Signed by Judge Alison J.
Nathan on 10/7/20)(jw) (Entered: 10/07/2020)</td></tr><tr><td>10/07/2020</td><td>63</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAs Maurene Comey, Alison Moe, and Lara Pomerantz dated October 7, 2020 re:
Review of Investigative Files from Other Offices and Agencies Document filed by
USA. (Comey, Maurene) (Entered: 10/07/2020)</td></tr><tr><td>10/14/2020</td><td>64</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated October 14, 2020 re: Response to 60 LETTER addressed to Judge
Alison J. Nathan from USA dated October 6, 2020 re: Request to Delay Disclosure.
(Everdell, Christian) (Entered: 10/14/2020)</td></tr><tr><td>10/20/2020</td><td>65</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated October 20, 2020 re:
Reply Letter in Further Support of Request to Delay Disclosure Document filed by
USA. (Comey, Maurene) (Entered: 10/20/2020)</td></tr><tr><td>10/23/2020</td><td>66</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Jeffrey S.
Pagliuca dated October 23, 2020 re: Response to the Governments October 7, 2020
letter (Pagliuca, Jeffrey) (Entered: 10/23/2020)</td></tr><tr><td>10/30/2020</td><td>67</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAs Maurene Comey, Alison Moe, and Lara Pomerantz dated October 30, 2020 re:
Reply to Defense's October 23, 2020 Letter Document filed by USA. (Comey,
Maurene) (Entered: 10/30/2020)</td></tr><tr><td>11/05/2020</td><td>68</td><td>ORDER as to Ghislaine Maxwell: This Order is entered, pursuant to Federal Rule of
Criminal Procedure 5(f) and the Due Process Protections Act, Pub. L. No 116182, 134
Stat. 894 (Oct. 21, 2020), to confirm the Government's disclosure obligations under
Brady v. Maryland, 373 U.S. 83 (1963), and its progeny, and to summarize the
possible consequences of violating those obligations. (Signed by Judge Alison J.
Nathan on 11/5/2020) (See ORDER set forth) (ap) (Entered: 11/05/2020)</td></tr></table>

# Case 21-58, Document 3-2, 01/12/2021, 3011691, Page14 of 20

<table><tr><th>11/06/2020</th><th>69</th><th>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated November 6, 2020
re: Request to Extend Discovery Deadline for Portion of Electronic Discovery
Document filed by USA. (Comey, Maurene) (Entered: 11/06/2020)</th></tr><tr><td>11/06/2020</td><td>70</td><td>AFFIDAVIT of Maurene Comey by USA as to Ghislaine Maxwell. (Comey, Maurene)
(Entered: 11/06/2020)</td></tr><tr><td>11/09/2020</td><td>71</td><td>MANDATE of USCA (Certified Copy) as to Ghislaine Maxwell re: 55 Notice of
Appeal. USCA Case Number 20-3061-cr. UPON DUE CONSIDERATION
WHEREOF, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that the
motion to consolidate is DENIED and the appeal is DISMISSED for want of
jurisdiction.. Catherine O'Hagan Wolfe, Clerk USCA for the Second Circuit. Issued As
Mandate: 11/09/2020. (nd) (Entered: 11/09/2020)</td></tr><tr><td>11/09/2020</td><td>72</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on 69 LETTER by USA as to
Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene
Comey, Alison Moe, and Lara Pomerantz dated November 6, 2020 re: Request to
Extend Discovery Deadline for Portion of Electronic Discovery. ENDORSEMENT:
The Court hereby extends the deadline for the Government's production of electronic
discovery from November 9, 2020 to November 23, 2020. The Court also grants the
parties' request for an extension of the motions deadlines as follows: the Defendant's
motions are due by January 11, 2021, the Government's responses are due by February
12, 2021, and any replies are due by February 19, 2021. SO ORDERED. (Discovery
due by 11/23/2020. Motions due by 1/11/2021. Responses due by 2/12/2021. Replies
due by 2/19/2021.) (Signed by Judge Alison J. Nathan on 11/9/2020) (Inl) (Entered:
11/10/2020)</td></tr><tr><td>11/18/2020</td><td>73</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 60 Letter filed by USA as
to Ghislaine Maxwell re: The Government respectfully requests that the Court approve
the Government's request to delay disclosure of these
Materials...ENDORSEMENT...There is no dispute that the materials referenced in the
Government's letter will be turned over to the defense. The Government has indicated
that it will do so. The only dispute, then, relates to the timing of such disclosure. See
Dkt. Nos. 64, 65. Because the Government has articulated plausible reasons for some
delay of disclosure, see Dkt. No. 65 at 4, the Court grants the Government's request to
delay disclosure. However, the Governments proposal to delay disclosure until 8
weeks in advance of trial is insufficient. In order to ensure that the defense can
adequately prepare for trial, the Government shall produce the referenced materials,
which are not voluminous, to the defense by March 12, 2021. Disclosure of the
materials will of course be subject to the protective order entered by the Court, see
Dkt. No. 36. (Government Responses due by 3/12/2021) (Signed by Judge Alison J.
Nathan on 11/18/20)(jw) (Entered: 11/18/2020)</td></tr><tr><td>11/23/2020</td><td>74</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated November 23, 2020
re: Update Regarding Conditions of Confinement Document filed by USA. (Comey,
Maurene) (Entered: 11/23/2020)</td></tr><tr><td>11/24/2020</td><td>75</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C.
Sternheim dated 11/24/2020 re: Response to 90-day MDC conditions report
(Sternheim, Bobbi) (Entered: 11/24/2020)</td></tr><tr><td>11/24/2020</td><td>76</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 75 LETTER by Ghislaine
Maxwell addressed to Judge Alison J. Nathan from Bobbi C. Sternheim dated
11/24/2020 re: Response to 90-day MDC conditions report. ENDORSEMENT: The
parties are hereby ORDERED to meet and confer regarding Defendant's request that
Warden Heriberto Tellez directly address Defendant's concerns regarding the
conditions of her detention. The parties shall jointly submit a status update within one
week of this Order. (Signed by Judge Alison J. Nathan on 11/24/2020) (ap) (Entered:
11/24/2020)</td></tr><tr><td>12/01/2020</td><td>77</td><td>ORDER as to Ghislaine Maxwell. On November 25, 2020, the Defendant filed a letter
request under seal. On November 30, 2020, she filed a second letter request in which
she proposed redactions on both letters. The Government is hereby ORDERED to
respond to the Defendant's November 25, 2020 letter request and to the request for
proposed redactions by no later than December 2, 2020. The letters shall be</td></tr></table>

# Case 21-58, Document 3-2, 01/12/2021, 3011691, Page15 of 20

<table><tr><th></th><th></th><th>temporarily sealed while the Court resolves the redaction request. SO ORDERED.
(Signed by Judge Alison J. Nathan on 12/1/2020)(bw) (Entered: 12/01/2020)</th></tr><tr><td>12/01/2020</td><td>78</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated December 1, 2020
re: Joint Letter regarding Conditions of Confinement Document filed by USA.
(Pomerantz, Lara) (Entered: 12/01/2020)</td></tr><tr><td>12/02/2020</td><td>79</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 78 LETTER by USA
addressed to Judge Alison J. Nathan from AUSAS Maurene Comey, Alison Moe, and
Lara Pomerantz dated December 1, 2020 re: Joint Letter regarding Conditions of
Confinement. ENDORSEMENT: MDC legal counsel shall submit their letter to the
Court by December 4, 2020. Upon review of that letter, the Court will determine
whether any additional information is required, either orally or in writing. SO
ORDERED. (Signed by Judge Alison J. Nathan on 12/2/2020)(bw) (Entered:
12/02/2020)</td></tr><tr><td>12/02/2020</td><td>80</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated December 2, 2020
re: Defense Requests for Sealing Document filed by USA. (Comey, Maurene)
(Entered: 12/02/2020)</td></tr><tr><td>12/03/2020</td><td>81</td><td>ORDER as to Ghislaine Maxwell. On November 25, 2020, counsel for Defendant
Ghislaine Maxwell filed a letter request seeking an in camera conference for the
presentation of a renewed motion for release on bail and a request to seal the
November 25, 2020 letter in its entirety. The Court required justification for the
sealing request. On November 30, 2020, the defense counsel filed a second letter no
longer fully pressing the unsupported request to file the letter entirely under seal and
instead proposing redactions to both the November 25th and November 30th letters.
The Government has indicated that it does not oppose the redactions. Dkt. No. 80.
After due consideration, the Court will adopt the Defendant's proposed redactions,
which are consented to by the Government. The Court's decision is guided by the
three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of
Onondaga, 435 F.3d 110 (2d Cir. 2006). Under this test, the Court must: (i) determine
whether the documents in question are "judicial documents;" (ii) assess the weight of
the common law presumption of access to the materials; and (iii) balance competing
considerations against the presumption of access. Id. at 11920. "Such countervailing
factors include but are not limited to 'the danger of impairing law enforcement or
judicial efficiency' and 'the privacy interests of those resisting disclosure."" Id. at 120
(quoting United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995) ("Amodeo II")).
The proposed redactions satisfy this test. First, the Court finds that the Defendant's
letter motions are "relevant to the performance of the judicial function and useful in
the judicial process," thereby qualifying as a "judicial document" for purposes of the
first element of the Lugosch test. United States v. Amodeo ("Amodeo I"), 44 F.3d 141,
145 (2d Cir. 1995). And while the Court assumes that the common law presumption of
access attaches, in balancing competing considerations against the presumption of
access, the Court finds that the arguments the Defendant has put forthincluding, most
notably, the privacy interests of the individuals referenced in the lettersfavor her
proposed and tailored redactions. The Defendant is hereby ORDERED to docket the
redacted versions of the two letters by December 4, 2020. For the reasons outlined in
the Government's letter dated December 2, 2020, Dkt. No. 80, the Court DENIES the
Defendant's request for an in camera conference. In order to protect the privacy
interests referenced in the Defendant's November 25, 2020 letter, the Court will permit
the Defendant to make her submission in writing and to propose narrowly tailored
redactions. The parties are hereby ORDERED to meet and confer and to jointly
prepare a briefing schedule for the Defendant's forthcoming renewed motion for
release on bail. SO ORDERED. (Signed by Judge Alison J. Nathan on 12/3/2020)(bw)
(Entered: 12/03/2020)</td></tr><tr><td>12/03/2020</td><td>82</td><td>SEALED DOCUMENT placed in vault. (jus) (Entered: 12/03/2020)</td></tr><tr><td>12/03/2020</td><td>83</td><td>SEALED DOCUMENT placed in vault. (jus) (Entered: 12/03/2020)</td></tr><tr><td>12/03/2020</td><td>84</td><td>SEALED DOCUMENT placed in vault. (jus) (Entered: 12/03/2020)</td></tr></table>

# Case 21-58, Document 3-2, 01/12/2021, 3011691, Page16 of 20

<table><tr><th>12/04/2020</th><th>85</th><th>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated December 4, 2020 re: Briefing Schedule (Everdell, Christian) (Entered:
12/04/2020)</th></tr><tr><td>12/04/2020</td><td>86</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated 11/25/2020 re: Sealing (Everdell, Christian) (Entered: 12/04/2020)</td></tr><tr><td>12/04/2020</td><td>87</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
| Everdell dated 11/30/2020 re: Sealing (Everdell, Christian) (Entered: 12/04/2020)</td></tr><tr><td>12/07/2020</td><td>88</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Sophia
Papapetru and John Wallace dated 12/4/20 re: This letter is written in response to your
order dated December 2, 2020, concerning Ghislaine Maxwell, Reg. 02879-509., an
inmate currently confined at the Metropolitan Detention center in Brooklyn, New
York. You expressed various concerns regarding Ms. Maxwells confinement and
well-being. (jw) (Entered: 12/07/2020)</td></tr><tr><td>12/07/2020</td><td>89</td><td>ORDER as to Ghislaine Maxwell re: 85 Letter filed by Ghislaine Maxwell. The Court
is in receipt of the Defendant's December 4, 2020 letter, Dkt. No. 85, and hereby sets
the following schedule: The Defendants submission is due December 8, 2020; The
Government's response is due December 16, 2020; The Defendant's reply is due
December 18, 2020. After reviewing these submissions, the Court will determine
whether a hearing on the renewed bail motion is necessary. The Court grants the
Defendants request that the Government shall file its submission under seal with
proposed redactions. Any objections to proposed redactions are due within 24 hours
after any brief has been filed. Finally, the Defendant is granted leave to file a motion
not to exceed 40 pages. The Governments response shall also be limited to 40 pages.
The Defendant's reply shall not exceed 10 pages (Defendant submission due by
12/8/2020., Defendant Replies due by 12/18/2020., Government Responses due by
12/16/2020) (Signed by Judge Alison J. Nathan on 12/7/20)(jw) (Entered: 12/07/2020)</td></tr><tr><td>12/07/2020</td><td>90</td><td>ENDORSED LETTER as to Ghislaine Maxwell addressed to Judge Alison J. Nathan
from Mark S. Cohen and Christian R. Everdell dated 11/25/20 re: On behalf of my
client, Ghislaine Maxwell, we plan to file a Renewed Motion for Release on Bail (the
"Motion") and respectfully request an in camera conference, with all counsel present,
to address the appropriate procedures for the filing and consideration of the Motion.
For the reasons explained below, we intend to request, pursuant to Fed. R. Crim. P.
49.1(d), that the Court permit the filing of portions of the Motion and certain
supporting materials under seal and require that any responsive materials be filed
under seal....ENDORSEMENT: The Court sees no basis for the sealing of this letter.
On or before December 2, 2020, Defendant shall justify why this letter should be
sealed (or redacted). Alternatively, the Defendant may file the letter on the public
docket by that date. The Court will take no action on the request pending resolution of
the initial sealing question. The Defendant's letter and this memorandum endorsement
will be temporarily sealed pending resolution of the sealing request. (Signed by Judge
Alison J. Nathan on 11/25/20)(jw) (Entered: 12/07/2020)</td></tr><tr><td>12/07/2020</td><td>91</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C.
Sternheim dated 12/07/2020 re: Response to MDC Report to Court re: conditions
(Sternheim, Bobbi) (Entered: 12/07/2020)</td></tr><tr><td>12/08/2020</td><td>92</td><td>ORDER as to Ghislaine Maxwell: On December 4, 2020, the Court received a letter
from MDC legal counsel responding to the concerns that the Defendant raised in her
November 24, 2020 letter. See Dkt. Nos. 75, 88; see also Dkt. No. 78. The Defendant
responded to the MDC legal counsel's letter on December 7, 2020, reiterating her
request that the Court summon Warden Heriberto Tellez to personally respond to
questions from the Court regarding the Defendant's conditions of confinement. See
Dkt. No. 91. Having carefully reviewed the parties' submissions, along with the MDC
legal counsel's December 4, 2020 letter, the Court DENIES the Defendant's request to
summon the Warden to personally appear and respond to questions. This resolves Dkt.
No. 75. Notwithstanding this, as originally provided in Dkt. No. 49, the Government
shall continue to submit written status updates detailing any material changes to the
conditions of Ms. Maxwell's confinement, with particular emphasis on her access to
legal materials, including legal mail and email, and her ability to communicate with
defense counsel. The updates shall also include information on the frequency of
searches of the Defendant. The Court hereby ORDERS the Government to submit
these written updates every 60 days. Furthermore, the Government shall take all</td></tr></table>

# Case 21-58, Document 3-2, 01/12/2021, 3011691, Page17 of 20

<table><tr><th></th><th></th><th>necessary steps to ensure that the Defendant continues to receive adequate access to
her legal materials and her ability to communicate with defense counsel. (Signed by
Judge Alison J. Nathan on 12/8/2020) (ap) (Entered: 12/08/2020)</th></tr><tr><td>12/10/2020</td><td>93</td><td>TRANSCRIPT of Proceedings as to Ghislaine Maxwell re: Conference held on
7/14/2020 before Judge Alison J. Nathan. Court Reporter/Transcriber: Kristen
Carannante, (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 12/31/2020. Redacted Transcript Deadline set for 1/11/2021. Release of
Transcript Restriction set for 3/10/2021. (McGuirk, Kelly) (Entered: 12/10/2020)</td></tr><tr><td>12/10/2020</td><td>94</td><td>NOTICE OF FILING OF OFFICIAL TRANSCRIPT as to Ghislaine Maxwell. Notice
is hereby given that an official transcript of a Conference proceeding held on
7/14/2020 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.... (McGuirk, Kelly) (Entered: 12/10/2020)</td></tr><tr><td>12/14/2020</td><td>95</td><td>ORDER as to Ghislaine Maxwell: On December 8, 2020, Defendant Ghislaine
Maxwell filed her renewed application for bail under seal with proposed redactions, in
accordance with this Court's December 7, 2020 Order, see Dkt. No. 89. The
Government did not file any opposition to the Defendant's proposed redactions. After
due consideration, the Court will adopt the Defendant's proposed redactions. The
Court's decision to adopt those redactions is guided by the three-part test articulated
by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir.
2006). Under this test, the Court must: (i) determine whether the documents in
question are "judicial documents;" (ii) assess the weight of the common law
presumption of access to the materials; and (iii) balance competing considerations
against the presumption of access. Id. at 11920. "Such countervailing factors include
but are not limited to the danger of impairing law enforcement or judicial efficiency'
and 'the privacy interests of those resisting disclosure." Id. at 120 (quoting United
States v. Amodeo, 71 F.3d 1044, 1048 (2d Cir. 1995) ("Amodeo II")). The proposed
redactions satisfy this test. The Court finds that Defendant's letter motions are
"relevant to the performance of the judicial function and useful in the judicial process,'
thereby qualifying as a "judicial document" for purposes of the first element of the
Lugosch test. United States v. Amodeo ("Amodeo I"), 44 F.3d 141, 145 (2d Cir. 1995).
And the Court also finds that the common law presumption of access attaches. Id. at
146; see also Nixon v. Warner Comme'ns, Inc., 435 U.S. 589, 602 (1978).
Nevertheless, in balancing competing considerations against the presumption of
access, the Court finds that the redactions are narrowly tailored to properly guard the
privacy interests of the individuals referenced in the Defendant's submission and in the
corresponding exhibits The Defendant is hereby ORDERED to docket the redacted
documents and corresponding exhibits. (Signed by Judge Alison J. Nathan on
12/14/2020) (ap) (Entered: 12/14/2020)</td></tr><tr><td>12/14/2020</td><td>96</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated December 8, 2020 re: Cover Letter for Renewed Bail Application
(Everdell, Christian) (Entered: 12/14/2020)</td></tr><tr><td>12/14/2020</td><td>97</td><td>MEMORANDUM OF LAW in Support by Ghislaine Maxwell re: Renewed Motion
for Bail. (Attachments: # 1 Exhibit A, #2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5
Exhibit E, #6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, #2 Exhibit I, # 10 Exhibit J, #
11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16
Exhibit P, #17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit
U, #22 Exhibit V, # 23 Exhibit W, # 24 Exhibit X)(Everdell, Christian) (Entered:
12/14/2020)</td></tr><tr><td>12/17/2020</td><td>98</td><td>NOTICE OF ATTORNEY APPEARANCE Andrew Rohrbach appearing for USA.
(Rohrbach, Andrew) (Entered: 12/17/2020)</td></tr><tr><td>12/18/2020</td><td>99</td><td>ORDER as to Ghislaine Maxwell: On December 16, 2020, the Government filed its
opposition to Defendant Ghislaine Maxwell's renewed application for bail. In
accordance with this Court's December 7, 2020 Order, see Dkt. No. 89, the
Government filed its materials under seal and proposed narrowly tailored redactions on</td></tr></table>

# Case 21-58, Document 3-2, 01/12/2021, 3011691, Page18 of 20

<table><tr><th></th><th></th><th>those materials. The Defendant did not file any opposition to the Government's
proposed redactions. The Court will adopt the Government's proposed redactions after
applying the three-part test articulated by the Second Circuit in Lugosch v. Pyramid
Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Under this test, the Court must: (i)
determine whether the documents in question are "judicial documents;" (ii) assess the
weight of the common law presumption access to the materials; and (iii) balance
competing considerations against the presumption of access. Id. at 11920. "Such
countervailing factors include but are not limited to 'the danger of impairing law
enforcement or judicial efficiency' and 'the privacy interests of those resisting
disclosure."" Id. at 120 (quoting United States v. Amodeo ("Amodeo II"), 71 F.3d
1044, 1050 (2d Cir. 1995)). The proposed redactions satisfy this test. The Court finds
that the Governments submissions are "relevant to the performance of the judicial
function and useful in the judicial process," thereby qualifying as a "judicial
document" for purposes of the first element of the Lugosch test. United States v.
Amodeo ("Amodeo I"), 44 F.3d 141, 145 (2d Cir. 1995). And the Court also finds that
the common law presumption of access attaches. Id. at 146; see also Nixon v. Warner
Comme'ns, Inc., 435 U.S. 589, 602 (1978). Nevertheless, the proposed redactions are
narrowly tailored to serve substantial interests, including, most importantly, third
parties' personal privacy interests. See Under Seal v. Under Seal, 273 F. Supp. 3d 460
467 (S.D.N.Y.2017). The Government is hereby ORDERED to docket the redacted
documents and corresponding exhibits by no later than December 18, 2 (Signed by
Judge Alison J. Nathan on 12/18/2020) (ap) (Entered: 12/18/2020)</th></tr><tr><td>12/18/2020</td><td>100</td><td>MEMORANDUM OF LAW in Opposition by USA as to Ghislaine Maxwell Renewed
Bail Motion. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Comey, Maurene) (Entered:
12/18/2020)</td></tr><tr><td>12/23/2020</td><td>101</td><td>ORDER as to Ghislaine Maxwell: On December 18, 2020, the Defendant filed her
reply to the Government's opposition to her renewed application for bail. In
accordance with this Court's December 7, 2020 Order, see Dkt. No. 89, she filed these
materials under seal and proposed narrowly tailored redactions on those materials. The
Government did not file any opposition to the Defendant's proposed redactions. The
Court will adopt the Defendant's proposed redactions after applying the three-part test
articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d
110 (2d Cir. 2006). Under this test, the Court must: (i) determine whether the
documents in question are "judicial documents;" (ii) assess the weight of the common
law presumption of access to the materials; and (iii) balance competing considerations
against the presumption of access. Id. at 11920. "Such countervailing factors include
but are not limited to 'the danger of impairing law enforcement or judicial efficiency'
and 'the privacy interests of those resisting disclosure." Id. at 120 (quoting United
States v. Amodeo ("Amodeo II"), 71 F.3d 1044, 1050 (2d Cir. 1995)). The proposed
redactions satisfy this test. The Court finds that the Defendant's submissions are
"relevant to the performance of the judicial function and useful in the judicial process,'
thereby qualifying as a "judicial document" for purposes of the first element of the
Lugosch test. United States v. Amodeo ("Amodeo Î"), 44 F.3d 141, 145 (2d Cir. 1995).
And the Court also finds that the common law presumption of access attaches. Id. at
146; see also Nixon v. Warner Comme'ns, Inc., 435 U.S. 589, 602 (1978). As with the
redactions to her renewed motion for bail, the proposed redactions here are narrowly
tailored to serve substantial interests, including, most importantly, third parties
personal privacy interests. See Under Seal v. Under Seal, 273 F. Supp. 3d 460, 467
|(S.D.N.Y. 2017). See also Dkt. No. 95. The Defendant is hereby ORDERED to docket
the redacted documents and corresponding exhibits by no later than December 23,
2020. SO ORDERED. (Signed by Judge Alison J. Nathan on 12/23/2020) (Inl)
(Entered: 12/23/2020)</td></tr><tr><td>12/23/2020</td><td>102</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated December 18, 2020 re: Cover Letter for Reply Memorandum for
Renewed Bail Application (Everdell, Christian) (Entered: 12/23/2020)</td></tr><tr><td>12/23/2020</td><td>103</td><td>REPLY MEMORANDUM OF LAW in Support by Ghislaine Maxwell re: Renewed
Motion for Bail. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Everdell, Christian)
(Entered: 12/23/2020)</td></tr><tr><td>12/28/2020</td><td>104</td><td>ORDER as to Ghislaine Maxwell. On December 8, 2020, Defendant Ghislaine
Maxwell filed a renewed motion for releaseon bail. Dkt No. 97. In an Opinion and
Order concurrently filed under temporary seal, the Court DENIES the Defendant's</td></tr></table>

# Case 21-58, Document 3-2, 01/12/2021, 3011691, Page19 of 20

<table><tr><th></th><th></th><th>motion. In light of the fact that the Opinion includes potentially confidential
information that should not be filed on the public docket, the Court will permit the
parties 48 hours to propose any redactions to the Courts Opinion and Order and to
justify those redactions by reference tothe Second Circuits decision in Lugosch v.
Pyramid Co. of Onondaga, 435 F.3d 110(2d Cir. 2006). After determining which, if
any, portions of the Opinion and Order should be redacted, the Court will file the
Opinion and Order on the public docket. As a result, the Court concludes that the
Government has met its burden of persuasion that the Defendant poses a flight risk and
that pretrial detention continues to be warranted. On or before December 30, 2020, the
parties are ORDERED to submit a joint letter indicating whether they propose any
redactions and the justification for any such proposal. This resolves Dkt No. 97.
(Signed by Judge Alison J. Nathan on 12/28/20)(jw) (Entered: 12/28/2020)</th></tr><tr><td>12/30/2020</td><td>105</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated December 30, 2020
re: Joint Letter re December 28, 2020 Opinion and Order Document filed by USA.
(Comey, Maurene) (Entered: 12/30/2020)</td></tr><tr><td>12/30/2020</td><td>106</td><td>OPINION AND ORDER as to Ghislaine Maxwell. Defendant Ghislaine Maxwell has
been indicted by a grand jury on charges of conspiracy to entice minors to travel to
engage in illegal sex acts, in violation of 18 U.S.C. § 371; enticing a minor to travel to
engage in illegal sex acts, in violation of 18 U.S.C. §§ 2422 and 2; conspiracy to
transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371;
transporting minors to participate in illegal sex acts, in violation of 18 U.S.C. §§ 2423
and 2; and two charges of perjury, in violation of 18 U.S.C. § 1623. The Court held a
lengthy bail hearing on July 14, 2020. After extensive briefing and argument at the
hearing, the Court concluded that the Defendant was a clear risk of flight and that no
conditions or combination of conditions would ensure her appearance. Defendant
Ghislaine Maxwells renewed motion for release on bail, Dkt. No. 97, is DENIED.
(Signed by Judge Alison J. Nathan on 12/28/20)(jw) (Entered: 12/30/2020)</td></tr><tr><td>12/31/2020</td><td>107</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated December 31, 2020 re: Extension of Time Document filed by Ghislaine
Maxwell. (Everdell, Christian) (Entered: 12/31/2020)</td></tr><tr><td>01/05/2021</td><td>108</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell (1) on 107 LETTER MOTION
addressed to Judge Alison J. Nathan from Christian R. Everdell dated December 31,
2020 re: Extension of Time. ENDORSEMENT: SO ORDERED. (Signed by Judge
Alison J. Nathan on 1/5/2021) (ap) (Entered: 01/05/2021)</td></tr><tr><td>01/05/2021</td><td></td><td>Set/Reset Deadlines as to Ghislaine Maxwell: Motions due by 1/25/2021. Responses
due by 2/26/2021. Replies due by 3/5/2021. (ap) (Entered: 01/05/2021)</td></tr><tr><td>01/08/2021</td><td>109</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated January 8, 2021 re: Extension of Time to File Notice of Appeal. Document filed
by Ghislaine Maxwell. (Everdell, Christian) (Entered: 01/08/2021)</td></tr><tr><td>01/11/2021</td><td>110</td><td>SEALED DOCUMENT placed in vault. (jus) (Entered: 01/11/2021)</td></tr><tr><td>01/11/2021</td><td>111</td><td>SEALED DOCUMENT placed in vault. (jus) (Entered: 01/11/2021)</td></tr><tr><td>01/11/2021</td><td>112</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell (1) denying 109 LETTER
MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell dated
January 8, 2021 re: Extension of Time to File Notice of Appeal. ENDORSEMENT:
The request is denied. Good cause for an extension of time to file a notice of appeal
has not been provided. SO ORDERED. (Signed by Judge Alison J. Nathan on
1/11/2021) (Inl) (Entered: 01/11/2021)</td></tr><tr><td>01/11/2021</td><td>113</td><td>NOTICE OF APPEAL by Ghislaine Maxwell from 104 Order. (nd) (Entered:
01/12/2021)</td></tr><tr><td>01/11/2021</td><td></td><td>Appeal Remark as to re: 113 Notice of Appeal by Ghislaine Maxwell. $505.00 Appeal
filing fee due. (nd) (Entered: 01/12/2021)</td></tr><tr><td>01/12/2021</td><td></td><td>Transmission of Notice of Appeal and Certified Copy of Docket Sheet as to Ghislaine
Maxwell to US Court of Appeals re: 113 Notice of Appeal. (nd) (Entered: 01/12/2021)</td></tr></table>

# Case 21-58, Document 3-2, 01/12/2021, 3011691, Page20 of 20

01/12/2021

Appeal Record Sent to USCA (Electronic File). Certified Indexed record on Appeal Electronic Files as to Ghislaine Maxwell re: 113 Notice of Appeal were transmitted to the U.S. Court of Appeals. (nd) (Entered: 01/12/2021)

# Case 21-58, Document 6, 01/12/2021, 3011775, Page1 of 1

NOTICE OF APPEARANCE FOR SUBSTITUTE, ADDITIONAL, OR AMICUS COUNSEL

Short Title: United States v. Maxwell
Docket No.: 21-58

Substitute, Additional, or Amicus Counsel's Contact Information is as follows:

Name: Maureen Comey
Firm: United States Attorney's Office for the Southern District of New York
Address: One St. Andrew's Plaza
Telephone: (212) 637-2324
Fax: (212) 637-2387
E-mail: maureen.comey@usdoj.gov

Appearance for: United States of America/Appellee (party/designation)

Select One:
[ ] Substitute counsel (replacing lead counsel: <empty>)
(name/firm)
[ ] Substitute counsel (replacing other counsel: <empty>)
(name/firm)
[x] Additional counsel (co-counsel with: Won S. Shin/U.S. Attorney's Office for the Southern District of New York)
(name/firm)
[ ] Amicus (in support of : <empty>)
(party/designation)

# Case 21-58, Document 6, 01/12/2021, 3011775, Page1 of 1 (cont.)

## CERTIFICATION

I certify that:
[x] I am admitted to practice in this Court and, if required by Interim Local Rule 46.1(a)(2), have renewed my admission on November 5, 2020 OR 
[ ] I applied for admission on <empty>.
Signature of Counsel: /s/Maureen Comey
Type or Print Name: Maureen Comey

# Case 21-58, Document 8, 01/12/2021, 3012026, Page1 of 1

NOTICE OF APPEARANCE FOR SUBSTITUTE, ADDITIONAL, OR AMICUS COUNSEL

Short Title: United States v. Maxwell
Docket No.: 21-58

Substitute, Additional, or Amicus Counsel's Contact Information is as follows:

Name: Lara Pomerantz
Firm: United States Attorney's Office for the Southern District of New York
Address: One St. Andrew's Plaza
Telephone: (212) 637-2343
Fax: <empty>
E-mail: lara.pomerantz@usdoj.gov

Appearance for: United States of America/Appellee (party/designation)

Select One:
[ ] Substitute counsel (replacing lead counsel: <empty>)
(name/firm)

[ ] Substitute counsel (replacing other counsel: <empty>)
(name/firm)

[x] Additional counsel (co-counsel with: Won S. Shin/U.S. Attorney's Office for the Southern District of New York)
(name/firm)

[ ] Amicus (in support of : <empty>)
(party/designation)

# Case 21-58, Document 8, 01/12/2021, 3012026, Page1 of 1 (cont.)

## CERTIFICATION

I certify that:
[x] I am admitted to practice in this Court and, if required by Interim Local Rule 46.1(a)(2), have renewed my admission on December 3, 2020 OR 
[ ] I applied for admission on <empty>.
Signature of Counsel: /s/ Lara Pomerantz
Type or Print Name: Lara Pomerantz

# Case 21-58, Document 12, 01/25/2021, 3020548, Page1 of 1

NOTICE OF APPEARANCE FOR SUBSTITUTE, ADDITIONAL, OR AMICUS COUNSEL

Short Title: USA v. MAXWELL
Docket No.: 21-58

Substitute, Additional, or Amicus Counsel's Contact Information is as follows:
Name: Bobbi C. Sternheim, Esq.
Firm: Law Offices of Bobbi C. Sternheim
Address: 33 West 19th Street - 4th Floor. New York, NY 10011
Telephone: 212-243-1100
Fax: 888-587-4737
E-mail: bc@sternheimlaw.com, ecf@sternheimlaw.com, bcrestner@mac.com

Appearance for: Appellant Ghislaine Maxwell (party/designation)

Select One:
[ ] Substitute counsel (replacing lead counsel:<empty>)
(name/firm)
[ ] Substitute counsel (replacing other counsel:<empty>)
(name/firm)
[x] Additional counsel (co-counsel with: Christian R. Everdell, Esq./ Cohen & Gresser, LLP)
(name/firm)
[ ] Amicus (in support of:<empty>)
(party/designation)

# Case 21-58, Document 12, 01/25/2021, 3020548, Page1 of 1 (cont.)

## CERTIFICATION

I certify that:

I certify that:
[x] I am admitted to practice in this Court and, if required by Interim Local Rule 46.1(a)(2), have renewed my admission on:<empty> OR
[ ] I applied for admission on:<empty>

Signature of Counsel: Bobbi C. Sternheim
Type or Print Name: Bobbi C. Sternheim, Esq.

Case 21-58, Document 13, 01/26/2021, 3021043, Page1 of 1

# ACKNOWLEDGMENT AND NOTICE OF APPEARANCE

Short Title: USA v. MAXWELL
Docket No.: 21-58

Lead Counsel of Record (name/firm) or Pro se Party (name): Christian R. Everdell, Esq./Cohen& Gresser, LLP
Appearance for (party/designation): Appellant Ghislaine Maxwell

# ACKNOWLEDGMENT AND NOTICE OF APPEARANCE (cont.)

## DOCKET SHEET ACKNOWLEDGMENT/AMENDMENTS

Caption as indicated is:
Correct
Incorrect. See attached caption page with corrections.



Appellate Designation is:

✓ Correct

Incorrect. The following parties do not wish to participate in this appeal:
Parties:

Incorrect. Please change the following parties' designations:
Party Correct Designation

Contact Information for Lead Counsel/Pro Se Party is: Correct Incorrect or Incomplete. As an e-filer, I have updated my contact information in the PACER "Manage My Account" screen.

Name: Christian R. Everdell, Esq.

Firm: Cohen & Gresser, LLP.

Address: 800 Third Avenue New York, NY 10022

Telephone: 212-957-7600

Fax: 212-957-4514

Email: ceverdell@cohengresser.com

## RELATED CASES

[ ] This case has not been before this Court previously.
[x] This case has been before this Court previously. The short title, docket number, and citation are: USA v. Maxwell 20-3061

[ ] Matters related to this appeal or involving the same issue have been or presently are before this Court. The short titles, docket numbers, and citations are:<empty>

# ACKNOWLEDGMENT AND NOTICE OF APPEARANCE (cont.)

## CERTIFICATION

I certify that [x] I am admitted to practice in this Court and, if required by LR 46.1(a)(2), have renewed my admission on <empty> OR that [ ] I applied for admission on <empty> or renewal on <empty> . If the Court has not yet admitted me or approved my renewal, I have completed Addendum A.
Signature of Lead Counsel of Record: /s/ Christian R. Everdell, Esq.
Type or Print Name: Christian R. Everdell, Esq.

OR

Signature of pro se litigant: <empty>
Type or Print Name: <empty>

[ ] I am a pro se litigant who is not an attorney.
[ ] I am an incarcerated pro se litigant.

Case 21-58, Document 14, 01/26/2021, 3021115, Page1 of 2

# United States Court of Appeals for the Second Circuit Thurgood Marshall U.S. Courthouse 40 Foley Square New York, NY 10007

DEBRA ANN LIVINGSTON
CHIEF JUDGE

Date: January 26, 2021 Docket #: 21-58 Short Title: United States of America v. Maxwell

CATHERINE O'HAGAN WOLFE
CLERK OF COURT

DC Docket #: 1:20-cr-330-1
DC Court: SDNY (NEW YORK
CITY)
DC Judge: Nathan

# NOTICE OF DEFECTIVE FILING

On January 25, 2021 the Acknowledgment and Notice of Appearance, on behalf of the Appellant, was submitted in the above referenced case. The document does not comply with the FRAP or the Court's Local Rules for the following reason:

# NOTICE OF DEFECTIVE FILING (cont.)

Failure to submit acknowledgment and notice of appearance (Local Rule 12.3) Failure to file the Record on Appeal (FRAP 10, FRAP 11) Missing motion information statement (T-1080 - Local Rule 27.1) Missing supporting papers for motion (e.g, affidavit/affirmation/declaration) (FRAP 27) Insufficient number of copies (Local Rules: 21.1, 27.1, 30.1, 31.1) Improper proof of service (FRAP 25) Missing proof of service Served to an incorrect address Incomplete service (Anders v. California 386 U.S. 738 (1967)) Failure to submit document in digital format (Local Rule 25.1) Not Text-Searchable (Local Rule 25.1, Local Rules 25.2), click here for instructions on how to make PDFs text searchable Failure to file appendix on CD-ROM (Local Rule 25.1, Local Rules 25.2) Failure to file special appendix (Local Rule 32.1) Defective cover (FRAP 32) Incorrect caption (FRAP 32) Wrong color cover (FRAP 32) Docket number font too small (Local Rule 32.1) Incorrect pagination, click here for instructions on how to paginate PDFs (Local Rule 32.1) Incorrect font (FRAP 32) Oversized filing (FRAP 27 (motion), FRAP 32 (brief)) Missing Amicus Curiae filing or motion (Local Rule 29.1) Untimely filing

Case 21-58, Document 14, 01/26/2021, 3021115, Page2 of 2

# X Incorrect Filing Event
X Other: You must use the event Acknowledgment and Notice of Appearance, filed.

Please cure the defect and resubmit the document, with the required copies if necessary, no later than N/A. The resubmitted documents, if compliant with FRAP and the Local Rules, will be deemed timely filed.

Failure to cure the defect by the date set forth above will result in the document being stricken. An appellant's failure to cure a defective filing may result in the dismissal of the appeal.

Inquiries regarding this case may be directed to 212-857-8577.

Case 21-58, Document 17, 01/26/2021, 3021312, Page1 of 2

# UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT CRIMINAL APPEAL TRANSCRIPT INFORMATION FORM B

TO BE COMPLETED BY ATTORNEY:

USA v. Maxwell

CASE NAME:

21-58
DOCKET NUMBER:

Christian R. Everdell, Esq. Cohen & Gresser, LLP

COUNSEL'S NAME:

800 Third Avenue New York, NY 10022
COUNSEL'S ADDRESS:

212-957-7600

COUNSEL'S PHONE:

## QUESTIONNAIRE

I am ordering a transcript.



I am not ordering a transcript. Reason:

Daily copy available U.S. Atty. placed order
Other (attach explanation)

# UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT CRIMINAL APPEAL TRANSCRIPT INFORMATION FORM B (cont.)

## TRANSCRIPT ORDER

Prepare transcript of
[ ] Pre-trial proceedings: <empty> (Description & Dates)
[ ] Trial: <empty> (Description & Dates)
[ ] Sentencing: <empty> (Description & Dates)
[ ] Post-trial proceedings: <empty> (Description & Dates)
I, <empty> , hereby certify that I will make satisfactory arrangements with
(counsel’s name)
the court reporter for payment of the costs of the transcript in accordance with FRAP 10(b).
Method of payment:
[ ] Funds
[ ] CJA Form 24
Counsel’s Signature: <empty>
Date: <empty>

## TO BE COMPLETED BY COURT REPORTER AND FORWARDED TO COURT OF APPEALS:

## ACKNOWLEDGMENT

Date order received: <empty>
Estimated Number of Pages: <empty>

Estimated completion date: <empty>

Court Reporter's Signature: <empty>
Date: <empty>

Attorney(s): Send completed form to the U.S. District Court as that court may require and send copies to the Court of Appeals, U.S. Attorney's Office, and Court Reporter. Court Reporter(s): Send completed acknowledgement to the Court of Appeals Clerk.

Case 21-58, Document 17, 01/26/2021, 3021312, Page2 of 2

USA v. MAXWELL 21-58

# Addendum to Form B

Reason no transcript is being ordered:

This is an interlocutory appeal from a decision and order adjudicated without a hearing, docketed in the district court (SDNY), and available on ECF.

Case 21-58, Document 20-1, 03/24/2021, 3065965, Page1 of 2

# United States Court of Appeals for the Second Circuit Thurgood Marshall U.S. Courthouse 40 Foley Square New York, NY 10007

DEBRA ANN LIVINGSTON
CHIEF JUDGE

CATHERINE O'HAGAN WOLFE
CLERK OF COURT

Date: March 29, 2021 Docket #: 21-770 Short Title: United States of America v. Maxwell

DC Docket #: 1:20-cr-330-1
DC Court: SDNY (NEW YORK
CITY)
DC Judge: Nathan

# DOCKETING NOTICE

# DOCKETING NOTICE (cont.)

An appeal in the above-referenced case has been docketed under number: 21-770. This number must appear on all documents related to this case that are filed in this Court. Appellate counsel of record either represented the appellant before the district court, filed the notice of appeal, or acted as counsel for appellee in the district court. For pro se parties the docket sheet with the caption page, and an Acknowledgment and Notice of Appearance Form are enclosed. In counseled cases the docket sheet is available on PACER. Counsel must access the Acknowledgment and Notice of Appearance Form from this Court's website http://www.ca2.uscourts.gov.

The form must be completed and returned within 14 days of the date of this notice. The form requires the following information:

YOUR CORRECT CONTACT INFORMATION: Review the party information on the docket sheet and note any incorrect information in writing on the Acknowledgment and Notice of Appearance Form.

# DOCKETING NOTICE (cont.)

The Court will contact one counsel per party or group of collectively represented parties when serving notice or issuing our order. Counsel must designate on the Acknowledgment and Notice of Appearance a lead attorney to accept all notices from this Court who, in turn will, be responsible for notifying any associated counsel.

CHANGE IN CONTACT INFORMATION: An attorney or pro se party who does not immediately notify the Court when contact information changes will not receive notices, documents and orders filed in the case.

Case 21-58, Document 20-1, 03/24/2021, 3065965, Page2 of 2

An attorney and any pro se party who is permitted to file documents electronically in CM/ECF must notify the Court of a change to the user's mailing address, business address, telephone number, or e-mail. To update contact information, a Filing User must access PACER's Manage My Appellate Filer Account, https://www.pacer.gov/psco/cgi-bin/cmecf/ea-login.pl. The Court's records will be updated within 1 business day of a user entering the change in PACER.

# DOCKETING NOTICE (cont.)

A pro se party who is not permitted to file documents electronically must notify the Court of a change in mailing address or telephone number by filing a letter with the Clerk of Court.

CAPTION: In an appeal, the Court uses the district court caption pursuant to FRAP 12(a), 32(a). For a petition for review or original proceeding the Court uses a caption pursuant to FRAP 15(a) or 21(a), respectively. Please review the caption carefully and promptly advise this Court of any improper or inaccurate designations in writing on the Acknowledgment and Notice of Appearance form. If a party has been terminated from the case the caption may reflect that change only if the district court judge ordered that the caption be amended.

APPELLATE DESIGNATIONS: Please review whether petitioner is listed correctly on the party listing page of the docket sheet and in the caption. If there is an error, please note on the Acknowledgment and Notice of Appearance Form. Timely submission of the Acknowledgment and Notice of Appearance Form will constitute compliance with the requirement to file a Representation Statement required by FRAP 12(b).

# DOCKETING NOTICE (cont.)

For additional information consult the Court's instructions posted on the website.

Inquiries regarding this case may be directed to 212-857-8577.

Caseat:20-150033 met 4/232 Filed603/24/1

Criminal Notice of Appeal Form A

DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 3/24/2021

# NOTICE OF APPEAL

United States District Court

Southern

District of New York

Caption:
United States of America v.
Ghislaine Maxwell
Docket No.: 20-CR-00330-AJN
Alison J. Nathan
(District Court Judge)
Notice is hereby given that Ghislaine Maxwell appeals to the United States Court of
Appeals for the Second Circuit from the judgment [ ] other | [x] Order on Third Motion for Release on Bail (Doc. 169)
entered in this action on March 22, 2021
(date)
(specify)
This appeal concerns: Conviction only [ ] Sentence only [ ] Conviction & Sentence [ ] Other [x]
Defendant found guilty by plea [ ] trial [ ] N/A |
Offense occurred after November 1, 1987? Yes | No [ ]
N/A |
Date of sentence: N/A |
Bail/Jail Disposition: Committed [x] Not committed | N/A |
Appellant is represented by counsel? Yes [x] No [ ] If yes, provide the following information:
Defendant's Counsel: David Oscar Markus
Counsel's Address: Markus/Moss PLLC
40 NW Third Street, Ph 1, Miami, Florida 33128
Counsel's Phone: (305)379-6667
Assistant U.S. Attorney: Maureen Comey, Alison Moe & Lara Pomerantz
AUSA's Address: The Silvio J. Mollo Building
One Saint Andrew's Plaza, New York, New York 10007
AUSA's Phone: (212)637-2324
<signature>

Signature

# NOTICE OF APPEAL (cont.)

Case 21-58, Document 20-2, 03/24/2021, 3065965, Page2 of 24

APPEAL,ECF,INTAPP

# U.S. District Court Southern District of New York (Foley Square) CRIMINAL DOCKET FOR CASE #: 1:20-cr-00330-AJN All Defendants

Case title: USA v. Maxwell

Date Filed: 06/29/2020

Assigned to: Judge Alison J.
Nathan

Appeals court case number:
21-0058 U.S. Court of Appeals,
2nd Circ.

# U.S. District Court Southern District of New York (Foley Square) CRIMINAL DOCKET FOR CASE #: 1:20-cr-00330-AJN All Defendants (cont.)

## Defendant (1)

Ghislaine Maxwell
also known as
Sealed Defendant 1

represented by Christian R. Everdell
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
212-707-7268
Fax: 212-957-4514
Email: ceverdell@cohengresser.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Jeffrey S. Pagliuca
Haddon Morgan and Foreman
150 East 10th Avenue
Denver, CO 80203
(303)-831-7364
Fax: (303)-832-2628
Email: ipagliuca@hmflaw.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Laura A. Menninger
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
(303)-831-7364
Fax: (303)-832-2628
Email: lmenninger@hmflaw.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Mark Stewart Cohen
Cohen & Gresser, LLP (NYC)
800 Third Avenue
New York, NY 10022
(212) 957-7600
Fax: (212)957-4514
Email: mcohen@cohengresser.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Bobbi C Sternheim
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
(212) 243-1100
Fax: (888) 587-4737
Email: bc@sternheimlaw.com

# Case 21-58, Document 20-2, 03/24/2021, 3065965, Page3 of 24

ATTORNEY TO BE NOTICED

Pending Counts

Disposition

18:371.F CONSPIRACY TO
ENTICE MINORS TO TRAVEL
TO ENGAGE IN ILLEGAL SEX
ACTS
(1)

18:371.F CONSPIRACY TO
ENTICE MINORS TO TRAVEL
TO ENGAGE IN ILLEGAL SEX
ACTS
(1s)

18:2422.F COERCION OR
ENTICEMENT OFA MINOT TO
TRAVEL TO ENGAGE IN
ILLEGAL SEX ACTS
(2)

18:2422.F COERCION OR
ENTICEMENT OF MINOR TO
ENGAGE IN ILLEGAL SEX
ACTS
(2s)

18:371.F CONSPIRACY TO
TRANSPORT MINORS WITH
INTENT TO ENGAGE IN
CRIMINAL SEXUAL ACTIVITY
(3)

18:371.F 18:371.F CONSPIRACY
TO TRANSPORT MINORS WITH
INTENT TO ENGAGE IN
CRIMINAL SEXUAL ACTIVITY
(3s)

18:2423.F COERCION OR
ENTICEMENT OF MINOR
FEMALE (TRANSPORTATION
OF A MINOR WITH INTENT TO
ENGAGE IN CRIMINAL
SEXUAL ACTIVITY)
(4)

18:2423.F TRANSPORTATION
OF A MINOR WITH INTENT TO
ENGAGE IN CRIMINAL
SEXUAL ACTIVITY
(4s)

18:1623.F FALSE
DECLARATIONS BEFORE
GRAND JURY/COURT
(PERJURY)
(5-6)

18:1623.F FALSE
DECLARATIONS BEFORE
GRAND JURY/COURT
(5s-6s)

## Highest Offense Level (Opening)

Felony

# Case 21-58, Document 20-2, 03/24/2021, 3065965, Page4 of 24

Terminated Counts

None

- Highest Offense Level
(Terminated)

None

Complaints
None

Plaintiff

USA

Disposition

Disposition

represented by Alex Rossmiller
U.S. Attorney's Office, Southern District of
New York
1 St. Andrew's Plaza
New York, NY 10007
(212) 637-2415
Email: alexander.rossmiller@usdoj.gov
LEAD ATTORNEY
PRO HAC VICE
ATTORNEY TO BE NOTICED
Designation: Assistant US Attorney

Alison Gainfort Moe
United States Attorney's Office, SDNY
One Saint Andrew's Plaza
New York, NY 10007
(212) 637-2225
Email: alison.moe@usdoj.gov
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Designation: Assistant US Attorney

Maurene Ryan Comey
United States Attorney's Office, SDNY
One Saint Andrew's Plaza
New York, NY 10007
(212) 637-2324
Email: maurene.comey@usdoj.gov
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Designation: Assistant US Attorney

Andrew Rohrbach
DOJ-USAO
1 St. Andrew's Plaza
New York, NY 10007
212-637-2345
Email: Andrew.Rohrbach@usdoj.gov
ATTORNEY TO BE NOTICED

Lara Elizabeth Pomerantz
United States Attorney's Office
One St. Andrew's Plaza
New York, NY 10007
212-637-2343
Fax: 212-637-2527
Email: Lara.Pomerantz@usdoj.gov
ATTORNEY TO BE NOTICED

# Case 21-58, Document 20-2, 03/24/2021, 3065965, Page5 of 24

<table><tr><th>Date Filed</th><th>#</th><th>Docket Text</th></tr><tr><td>06/29/2020</td><td>1</td><td>SEALED INDICTMENT as to Sealed Defendant 1 (1) count(s) 1, 2, 3, 4, 5-6. (jm)
(Main Document 1 replaced on 7/2/2020) (jm). (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td>2</td><td>Order to Unseal Indictment as to Sealed Defendant 1. (Signed by Magistrate Judge
Katharine H. Parker on 7/2/20)(jm) (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td></td><td>| INDICTMENT UNSEALED as to Ghislaine Maxwell. (jm) (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td></td><td>Case Designated ECF as to Ghislaine Maxwell. (jm) (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td></td><td>Case as to Ghislaine Maxwell ASSIGNED to Judge Alison J. Nathan. (jm) (Entered:
07/02/2020)</td></tr><tr><td>07/02/2020</td><td></td><td>Attorney update in case as to Ghislaine Maxwell. Attorney Alex Rossmiller, Maurene
Ryan Comey,Alison Gainfort Moe for USA added. (jm) (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td>4</td><td>MOTION to detain defendant. Document filed by USA as to Ghislaine Maxwell.
(Moe, Alison) (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td></td><td>Arrest of Ghislaine Maxwell in the United States District Court - District of New
Hampshire. (jm) (Entered: 07/06/2020)</td></tr><tr><td>07/05/2020</td><td>5</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Alex Rossmiller dated July 5, 2020 re:
Request to Schedule Initial Appearance Document filed by USA. (Comey, Maurene)
(Entered: 07/05/2020)</td></tr><tr><td>07/06/2020</td><td>6</td><td>Rule 5(c)(3) Documents Received as to Ghislaine Maxwell from the United States
District Court District of New Hampshire. (jm) (Entered: 07/06/2020)</td></tr><tr><td>07/06/2020</td><td>7</td><td>ORDER as to Ghislaine Maxwell. This matter has been assigned to me for all
purposes. In its July 5, 2020 letter, the Government on behalf of the parties requested
that the Court schedule an arraignment, initial appearance, and bail hearing in this
matter in the afternoon of Friday, July 10. See Dkt. No. 5. In light of the COVID
public health crisis, there are significant safety issues related to in-court proceedings.
If the Defendant is willing to waive her physical presence, this proceeding will be
conducted remotely. To that end, defense counsel should confer with the Defendant
regarding waiving her physical presence. If the Defendant wishes to waive her
physical presence for this proceeding, she and her counsel should sign the attached
form in advance of the proceeding if feasible. If this proceeding is to be conducted
remotely, there are protocols at the Metropolitan Detention Center that limit the times
at which the Defendant could be produced so that she could appear by video. In the
next week, the Defendant could be produced by video at either 9:00 a.m. on July 9,
2020 or sometime during the morning of July 14, 2020. Counsel are hereby ordered to
meet and confer regarding scheduling for this initial proceeding in light of these
constraints. If counsel does anticipate proceeding remotely, by 9:00 p.m. tonight,
counsel should file a joint letter proposing a date and time for the proceeding
consistent with this scheduling information, as well as a revised briefing schedule for
the Defendant's bail application.SO ORDERED. (Signed by Judge Alison J. Nathan on
7/6/2020)(jbo) (Entered: 07/06/2020)</td></tr><tr><td>07/06/2020</td><td>8</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Mark S.
Cohen dated July 6, 2020 re: Scheduling (Cohen, Mark) (Entered: 07/06/2020)</td></tr><tr><td>07/07/2020</td><td>2</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
Alex Rossmiller dated July 7, 2020 re: scheduling Document filed by USA.
(Rossmiller, Alex) (Entered: 07/07/2020)</td></tr><tr><td>07/07/2020</td><td>10</td><td>ORDER as to Ghislaine Maxwell. An arraignment, initial conference, and bail hearing
in this matter is hereby scheduled to occur as a remote video/teleconference using an
internet platform on July 14, 2020 at 1 p.m. In advance of the conference, Chambers
will email counsel with further information on how to access the video conference. To
optimize the quality of the video feed, only the Court, the Defendant, defense counsel,
and counsel for the Government will appear by video for the proceeding; all others
may access the audio of the public proceeding by telephone. Due to the limited</td></tr></table>

# Case 21-58, Document 20-2, 03/24/2021, 3065965, Page6 of 24

<table><tr><th></th><th></th><th>capacity of the internet platform system, only one attorney per party may participate
by video. Co-counsel, members of the press, and the public may access the audio feed
of the proceeding by calling a dial-in number, which the Court will provide in
advance of the proceeding by subsequent order. Given the high degree of public
interest in this case, a video feed of the remote proceeding will be available for
viewing in the Jury Assembly Room located at the Daniel Patrick Moynihan
Courthouse, 500 Pearl Street, New York, NY. Due to social distancing requirements,
seating will be extremely limited; when capacity is reached no additional persons will
be admitted. Per the S.D.N.Y. COVID-19 Courthouse Entry Program, anyone who
appears at any S.D.N.Y. courthouse must complete a questionnaire on the date of the
proceeding prior to arriving at the courthouse. All visitors must also have their
temperature taken when they arrive at the courthouse. Please see the instructions,
attached. Completing the questionnaire ahead of time will save time and effort upon
entry. Only persons who meet the entry requirements established by the questionnaire
and whose temperatures are below 100.4 degrees will be allowed to enter the
courthouse. Face coverings that cover the nose and mouth must be worn at all times.
| Anyone who fails to comply with the COVID-19 protocols that have been adopted by
the Court will be required to leave the courthouse. There are no exceptions. As
discussed in the Court's previous order, defense counsel shall, if possible, discuss the
Waiver of Right to be Present at Criminal Proceeding with the Defendant prior to the
proceeding. See Dkt. No. 7. If the Defendant consents, and is able to sign the form
(either personally or, in accordance with Standing Order 20-MC-174 of March 27,
2020, by defense counsel), defense counsel shall file the executed form at least 24
hours prior to the proceeding. In the event the Defendant consents, but counsel is
unable to obtain or affix the Defendant's signature on the form, the Court will conduct
an inquiry at the outset of the proceeding to determine whether it is appropriate for the
Court to add the Defendant's signature to the form. Pursuant to 18 U.S.C. § 3771(c)(1),
the Government must make their best efforts to see that crime victims are notified of,
and accorded, the rights provided to them in that section. This includes [t]he right to
reasonable, accurate, and timely notice of any public court proceeding... involving the
crime or of any release... of the accused and "[t]he right to be reasonably heard at any
public proceeding in the district court involving release." Id. § 3771(a)(2), (4). The
Court will inquire with the Government as to the extent of those efforts. So that
appropriate logistical arrangements can be made, the Government shall inform the
Court by email within 24 hours in advance of the proceeding if any alleged victim
wishes to be heard on the question of detention pending trial. Finally, the time between
the Defendant's arrest and July 6, 2020 is excluded under the Speedy Trial Act due to
the delay involved in transferring the Defendant from another district. See 18 U.S.C. §
3161(h)(1)(F). And the Court further excludes time under the Speedy Trial Act from
today through July 14, 2020. Due to the logistical issues involved in conducting a
remote proceeding, the Court finds "that the ends of justice served by [this exclusion]
outweigh the best interest of the public and the defendant in a speedy trial." 18 U.S.C.
§ 3161(h)(7)(A). The exclusion is also supported by the need for the parties to discuss
a potential protective order, which will facilitate the timely production of discovery in
a manner protective of the rights of third parties. See Dkt. No. 5. SO ORDERED.
(Signed by Judge Alison J. Nathan on 7/7/2020)(jbo) (Entered: 07/07/2020)</th></tr><tr><td>07/08/2020</td><td>11</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on 2 LETTER by USA as to
Ghislaine Maxwell addressed to Judge Alison J. Nathan from Alex Rossmiller dated
July 7, 2020 re: scheduling. ENDORSEMENT: The Court hereby sets the following
briefing schedule. The Defense response is due by 1:00 p.m. on July 10, 2020. The
Government reply is due by 1:00 p.m. on July 13, 2020. Additionally, defense counsel
is ordered to file notices of appearance on the docket by the end of the day today. SO
ORDERED. (Responses due by 7/10/2020. Replies due by 7/13/2020.) (Signed by
Judge Alison J. Nathan on 7/8/2020) (Inl) (Entered: 07/08/2020)</td></tr><tr><td>07/08/2020</td><td>12</td><td>NOTICE OF ATTORNEY APPEARANCE: Mark Stewart Cohen appearing for
| Ghislaine Maxwell. Appearance Type: Retained. (Cohen, Mark) (Entered: 07/08/2020)</td></tr><tr><td>07/08/2020</td><td>13</td><td>NOTICE OF ATTORNEY APPEARANCE: Christian R. Everdell appearing for
Ghislaine Maxwell. Appearance Type: Retained. (Everdell, Christian) (Entered:
07/08/2020)</td></tr><tr><td>07/08/2020</td><td>14</td><td>NOTICE OF ATTORNEY APPEARANCE: Laura A. Menninger appearing for
Ghislaine Maxwell. Appearance Type: Retained. (Menninger, Laura) (Entered:</td></tr></table>

# Case 21-58, Document 20-2, 03/24/2021, 3065965, Page7 of 24

<table><tr><th></th><th></th><th>07/08/2020)</th></tr><tr><td>07/08/2020</td><td>15</td><td>MOTION for Jeffrey S. Pagliuca to Appear Pro Hac Vice. Filing fee $ 200.00, receipt
number ANYSDC-20605229. Motion and supporting papers to be reviewed by
Clerk's Office staff. Document filed by Ghislaine Maxwell. (Attachments: # 1 Exhibit
Declaration of Jeffrey S. Pagliuca, # 2 Exhibit Certificate of Good Standing, #3 Text
of Proposed Order Proposed Order)(Pagliuca, Jeffrey) (Entered: 07/08/2020)</td></tr><tr><td>07/08/2020</td><td>17</td><td>(S1) SUPERSEDING INDICTMENT FILED as to Ghislaine Maxwell (1) count(s) 1s,
2s, 3s, 4s, 5s-6s. (jm) (Entered: 07/10/2020)</td></tr><tr><td>07/09/2020</td><td></td><td>|&gt;&gt;&gt;NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document
No. 15 MOTION for Jeffrey S. Pagliuca to Appear Pro Hac Vice. Filing fee $
200.00, receipt number ANYSDC-20605229. Motion and supporting papers to be
reviewed by Clerk's Office staff. The document has been reviewed and there are
no deficiencies. (aea) (Entered: 07/09/2020)</td></tr><tr><td>07/09/2020</td><td>16</td><td>ORDER as to Ghislaine Maxwell. As discussed in its previous order, the Court will
hold an arraignment, initial conference, and bail hearing in this matter remotely as a
video/teleconference on July 14, 2020 at 1 pm. Members of the press and the public in
the United States may access the live audio feed of the proceeding by calling
855-268-7844 and using access code 32091812# and PIN 9921299#. Those outside of
the United States may access the live audio feed by calling 214-416-0400 and using
the same access code and PIN. These phone lines can accommodate approximately
500 callers on a first come, first serve basis. The Court will provide counsel for both
sides an additional dial-in number to be used to ensure audio access to the proceeding
for non-speaking co-counsel, alleged victims, and any family members of the
Defendant. The United States Attorney's Office should email Chambers with
information regarding any alleged victims who are entitled, pursuant to 18 U.S.C.
$3771(a)(4), to be heard at the bail hearing and who wish to be heard. The Court will
then provide information as to the logistics for their dial-in access. As the Court
described in a previous order, members of the press and public may watch and listen to
the live video feed in the Jury Assembly Room, at the Daniel Patrick Moynihan
Courthouse, 500 Pearl Street. See Dkt. No. 10. However, in light of COVID-19,
seating will be limited to approximately 60 seats in order to enable appropriate social
distancing and ensure public safety. Counsel for the Defendant and the Government
may contact Chambers by email if there is a request to accommodate alleged victims
or family members of the Defendant. Members of the credentialed in-house press
corps may contact the District Executive's Office about seating. Otherwise, all seating
will be allocated on a first come, first serve basis and in accordance with the S.D.N.Y.
| COVID-19 Courthouse Entry Program and this Court's previous order of July 7, 2020.
|See Dkt. No. 10. If conditions change or the Court otherwise concludes that allowing
for in-person viewing of the video feed at the courthouse is not consistent with public
health, the Court may provide audio access by telephone only. Any photographing,
recording, or rebroadcasting of federal court proceedings is prohibited by law.
Violation of these prohibitions may result in fines or sanctions, including removal of
court issued media credentials, restricted entry to future hearings, denial of entry to
future hearings, or any other sanctions deemed necessary by the Court. SO
ORDERED. (Signed by Judge Alison J. Nathan on 7/9/2020)(jbo) (Entered:
07/09/2020)</td></tr><tr><td>07/10/2020</td><td>18</td><td>MEMORANDUM in Opposition by Ghislaine Maxwell re 4 MOTION to detain
defendant.. (Cohen, Mark) (Entered: 07/10/2020)</td></tr><tr><td>07/10/2020</td><td>19</td><td>NOTICE OF ATTORNEY APPEARANCE: Mark Stewart Cohen appearing for
| Ghislaine Maxwell. Appearance Type: Retained. (Cohen, Mark) (Entered: 07/10/2020)</td></tr><tr><td>07/10/2020</td><td>20</td><td>NOTICE OF ATTORNEY APPEARANCE: Christian R. Everdell appearing for
Ghislaine Maxwell. Appearance Type: Retained. (Everdell, Christian) (Entered:
07/10/2020)</td></tr><tr><td>07/10/2020</td><td>21</td><td>WAIVER of Personal Appearance at Arraignment and Entry of Plea of Not Guilty by
Ghislaine Maxwell. (Everdell, Christian) (Entered: 07/10/2020)</td></tr><tr><td>07/13/2020</td><td>22</td><td>REPLY MEMORANDUM OF LAW in Support by USA as to Ghislaine Maxwell re:
4 MOTION to detain defendant. . (Moe, Alison) (Entered: 07/13/2020)</td></tr></table>

# Case 21-58, Document 20-2, 03/24/2021, 3065965, Page8 of 24

<table><tr><th>07/13/2020</th><th></th><th>ORDER granting 15 Motion for Jeffrey Pagliuca to Appear Pro Hac Vice as to
Ghislaine Maxwell (1). (Signed by Judge Alison J. Nathan on 7/13/2020) (kwi)
(Entered: 07/13/2020)</th></tr><tr><td>07/14/2020</td><td>23</td><td>ORDER as to Ghislaine Maxwell. For the reasons stated on the record at today's
proceeding, the Governments motion to detain the Defendant pending trial is hereby
GRANTED (Signed by Judge Alison J. Nathan on 7/14/20)(jw) (Entered: 07/14/2020)</td></tr><tr><td>07/14/2020</td><td></td><td>Minute Entry for proceedings held before Judge Alison J. Nathan:Arraignment as to
Ghislaine Maxwell (1) Count 1s,2s,3s, 4s, 5s-6s held on 7/14/2020. Defendant
Ghislaine Maxwell present by video conference with attorney Mark Cohen present by
video conference, AUSA Alison Moe, Alex Rossmiller and Maurene Comey for the
government present by video conference, Pretrial Service Officer Lea Harmon present
by telephone and Court Reporter Kristine Caraannante. Defendant enters a plea of Not
Guilty to the S1 indictment. Trial set for July 12, 2021. See Order. Time is excluded
under the Speedy Trial Act from today until July 12, 2021. Bail is denied. Defendant is
| remanded. See Transcript. (jw) (Entered: 07/14/2020)</td></tr><tr><td>07/14/2020</td><td></td><td>Minute Entry for proceedings held before Judge Alison J. Nathan: Plea entered by
Ghislaine Maxwell (1) Count 1s,2s,3s, 4s, 5s-6s Not Guilty. (jw) (Entered: 07/14/2020)</td></tr><tr><td>07/14/2020</td><td>24</td><td>Waiver of Right to be Present at Criminal Proceeding as to Ghislaine Maxwell re:
Arraignment, Bail Hearing, Conference. (jw) (Entered: 07/14/2020)</td></tr><tr><td>07/15/2020</td><td>25</td><td>ORDER as to Ghislaine Maxwell. Initial non-electronic discovery, generally to
include search warrant applications and subpoena returns, is due by Friday, August 21,
2020. Completion of discovery, to include electronic materials, is due by Monday,
November 9, 2020. Motions are due by Monday, December 21, 2020. Motion
responses are due by Friday, January 22, 2021. Motion replies are due by Friday,
February 5, 2021. Trial is set for Monday, July 12, 2021 (Discovery due by
8/21/2020., Motions due by 12/21/2020) (Signed by Judge Alison J. Nathan on
7/15/20)(jw) (Entered: 07/15/2020)</td></tr><tr><td>07/21/2020</td><td>26</td><td>ORDER as to Ghislaine Maxwell: The Court has received a significant number of
letters and messages from non-parties that purport to be related to this case. These
submissions are either procedurally improper or irrelevant to the judicial function.
Therefore, they will not be considered or docketed. The Court will accord the same
treatment to any similar correspondence it receives in the future. SO ORDERED.
(Signed by Judge Alison J. Nathan on 7/21/2020) (Inl) (Entered: 07/21/2020)</td></tr><tr><td>07/21/2020</td><td>27</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Jeffrey S. Pagliuca
dated July 21, 2020 re: Local Criminal Rule 23.1. Document filed by Ghislaine
Maxwell. (Pagliuca, Jeffrey) (Entered: 07/21/2020)</td></tr><tr><td>07/23/2020</td><td>28</td><td>ORDER as to Ghislaine Maxwell: The Defense has moved for an order "prohibiting
the Government, its agents and counsel for witnesses from making extrajudicial
statements concerning this case." Dkt. No. 27 at 1. The Court firmly expects that
counsel for all involved parties will exercise great care to ensure compliance with this
| Court's local rules, including Local Criminal Rule 23.1, and the rules of professional
responsibility. In light of this clear expectation, the Court does not believe that further
action is needed at this time to protect the Defendant's right to a fair trial by an
impartial jury. Accordingly, it denies the Defendant's motion without prejudice. But
the Court warns counsel and agents for the parties and counsel for potential witnesses
that going forward it will not hesitate to take appropriate action in the face of
| violations of any relevant rules. The Court will ensure strict compliance with those
rules and will ensure that the Defendant's right to a fair trial will be safeguarded.
(Signed by Judge Alison J. Nathan on 7/23/2020) (ap) (Entered: 07/23/2020)</td></tr><tr><td>07/27/2020</td><td>29</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated July 27, 2020 re: Proposed Protective Order. Document filed by Ghislaine
Maxwell. (Attachments: # 1 Exhibit A (Proposed Protective Order))(Everdell,
Christian) (Entered: 07/27/2020)</td></tr><tr><td>07/27/2020</td><td>30</td><td>AFFIDAVIT of Christian R. Everdell by Ghislaine Maxwell. (Everdell, Christian)
(Entered: 07/27/2020)</td></tr><tr><td>07/27/2020</td><td>31</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
Alison Moe dated July 27, 2020 re: requesting until 5 p.m. tomorrow to respond to</td></tr></table>

# Case 21-58, Document 20-2, 03/24/2021, 3065965, Page9 of 24

<table><tr><th></th><th></th><th>defense counsel's letter, filed July 27, 2020 Document filed by USA. (Moe, Alison)
(Entered: 07/27/2020)</th></tr><tr><td>07/27/2020</td><td>32</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on 31 LETTER by USA as to
Ghislaine Maxwell addressed to Judge Alison J. Nathan from Alison Moe dated July
27, 2020 re: requesting until 5 p.m. tomorrow to respond to defense counsel's letter,
filed July 27, 2020. ENDORSEMENT: The Government's response to the Defense's
letter is due by 5 p.m. on July 28, 2020. The Defense may file a reply by 5 p.m. on
July 29, 2020. Before the Government's response is filed, the parties must meet and
confer by phone regarding this issue, and any response from the Government must
contain an affirmation that the parties have done so. SO ORDERED. (Responses due
by 7/28/2020. Replies due by 7/29/2020.) (Signed by Judge Alison J. Nathan on
7/27/2020) (Inl) (Entered: 07/27/2020)</td></tr><tr><td>07/28/2020</td><td>33</td><td>LETTER RESPONSE to Motion by USA as to Ghislaine Maxwell addressed to Judge
Alison J. Nathan from Alex Rossmiller dated July 28, 2020 re: 29 LETTER MOTION
addressed to Judge Alison J. Nathan from Christian R. Everdell dated July 27, 2020 re:
Proposed Protective Order.. (Attachments: # 1 Exhibit A (proposed protective
order))(Rossmiller, Alex) (Entered: 07/28/2020)</td></tr><tr><td>07/28/2020</td><td>34</td><td>AFFIDAVIT of Alex Rossmiller by USA as to Ghislaine Maxwell. (Rossmiller, Alex)
(Entered: 07/28/2020)</td></tr><tr><td>07/29/2020</td><td>35</td><td>LETTER REPLY TO RESPONSE to Motion by Ghislaine Maxwell addressed to
Judge Alison J. Nathan from Christian R. Everdell dated July 29, 2020 re 29 LETTER
MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell dated July
27, 2020 re: Proposed Protective Order .. (Everdell, Christian) (Entered: 07/29/2020)</td></tr><tr><td>07/30/2020</td><td>36</td><td>PROTECTIVE ORDER as to Ghislaine Maxwell...regarding procedures to be
followed that shall govern the handling of confidential material. SO ORDERED:
(Signed by Judge Alison J. Nathan on 7/30/2020)(bw) (Entered: 07/31/2020)</td></tr><tr><td>07/30/2020</td><td>37</td><td>MEMORANDUM OPINION &amp; ORDER as to Ghislaine Maxwell. Both parties have
asked for the Court to enter a protective order. While they agree on most of the
language, two areas of dispute have emerged. First, Ms. Maxwell seeks language
allowing her to publicly reference alleged victims or witnesses who have spoken on
the public record to the media or in public fora, or in litigation relating to Ms. Maxwell
or Jeffrey Epstein. Second, Ms. Maxwell seeks language restricting potential
Government witnesses and their counsel from using discovery materials for any
purpose other than preparing for the criminal trial in this action. The Government has
proposed contrary language on both of these issues. For the following reasons, the
Court adopts the Government's proposed protective order Under Federal Rule of
Criminal Procedure 16(d)(1), "[a]t any time the court may, for good cause, deny,
restrict, or defer discovery or inspection, or grant other appropriate relief." The good
cause standard "requires courts to balance several interests, including whether
dissemination of the discovery materials inflicts hazard to others... whether the
imposition of the protective order would prejudice the defendant," and "the public's
interest in the information." United States v. Smith, 985 F. Supp. 2d 506, 522
| (S.D.N.Y. 2013). The party seeking to restrict disclosure bears the burden of showing
good cause. Cf. Gambale v. Deutsche Bank AG, 377 F.3d 133, 142 (2d Cir. 2004).
First, the Court finds that the Government has met its burden of showing good cause
with regard to restricting the ability of Ms. Maxwell to publicly reference alleged
victims and witnesses other than those who have publicly identified themselves in this
litigation. As a general matter, it is undisputed that there is a strong and specific
interest in protecting the privacy of alleged victims and witnesses in this case that
supports restricting the disclosure of their identities. Dkt. No. 29 at 3 (acknowledging
that as a baseline the protective order should "prohibit[] Ms. Maxwell, defense
counsel, and others on the defense team from disclosing or disseminating the identity
of any alleged victim or potential witness referenced in the discovery materials"); see
also United States v. Corley, No. 13-cr-48, 2016 U.S. Dist. LEXIS 194426, at *11
(S.D.N.Y. Jan. 15, 2016). The Defense argues this interest is significantly diminished
for individuals who have spoken on the public record about Ms. Maxwell or Jeffrey
Epstein, because they have voluntarily chosen to identify themselves. But not all
accusations or public statements are equal. Deciding to participate in or contribute to a
| criminal investigation or prosecution is a far different matter than simply making a
public statement "relating to" Ms. Maxwell or Jeffrey Epstein, particularly since such a</td></tr></table>

# Case 21-58, Document 20-2, 03/24/2021, 3065965, Page 10 of 24

<table><tr><th></th><th></th><th>statement might have occurred decades ago and have no relevance to the charges in
this case. These individuals still maintain a significant privacy interest that must be
safeguarded. The exception the Defense seeks is too broad and risks undermining the
protections of the privacy of witnesses and alleged victims that is required by law. In
contrast, the Government's proffered language would allow Ms. Maxwell to publicly
reference individuals who have spoken by name on the record in this case. It also
allows the Defense to "referenc[e] the identities of individuals they believe may be
relevant... to Potential Defense Witnesses and their counsel during the course of the
investigation and preparation of the defense case at trial." Dkt. No. 33-1, 5. This
proposal adequately balances the interests at stake. And as the Government's letter
notes, see Dkt. No. 33 at 4, to the extent that the Defense needs an exception to the
protective order for a specific investigative purpose, they can make applications to the
Court on a case-by-case basis. Second, restrictions on the ability of potential
witnesses and their counsel to use discovery materials for purposes other than
preparing for trial in this case are unwarranted. The request appears unprecedented
despite the fact that there have been many high-profile criminal matters that had
related civil litigation. The Government labors under many restrictions including Rule
6(e) of the Federal Rules of Criminal Procedure, the Privacy Act of 1974, and other
policies of the Department of Justice and the U.S. Attorney's Office for the Southern
District of New York, all of which the Court expects the Government to scrupulously
follow. Furthermore, the Government indicates that it will likely only provide potential
witnesses with materials that those witnesses already have in their possession. See Dkt.
No. 33 at 6. And of course, those witnesses who do testify at trial would be subject to
| examination on the record as to what materials were provided or shown to them by the
Government. Nothing in the Defense's papers explains how its unprecedented
proposed restriction is somehow necessary to ensure a fair trial. For the foregoing
reasons, the Court adopts the Government's proposed protective order, which will be
entered on the docket. This resolves Dkt. No. 29. SO ORDERED. (Signed by Judge
Alison J. Nathan on 7/30/2020)(bw) (Entered: 07/31/2020)</th></tr><tr><td>08/10/2020</td><td>38</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated August 10, 2020 re: Discovery Disclosure and Access. Document filed by
Ghislaine Maxwell. (Everdell, Christian) (Entered: 08/10/2020)</td></tr><tr><td>08/10/2020</td><td>39</td><td>AFFIDAVIT of Christian R. Everdell by Ghislaine Maxwell. (Everdell, Christian)
(Entered: 08/10/2020)</td></tr><tr><td>08/11/2020</td><td>40</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 38 LETTER MOTION
addressed to Judge Alison J. Nathan from Christian R. Everdell dated August 10, 2020
re: Discovery Disclosure and Access. ENDORSEMENT: The Government is hereby
ORDERED to respond to the Defendant's letter motion by Thursday, August 13, 2020.
The Defendant's reply, if any, is due on or before Monday, August 17, 2020.
(Responses due by 8/13/2020. Replies due by 8/17/2020) (Signed by Judge Alison J.
Nathan on 8/11/2020) (ap) (Entered: 08/11/2020)</td></tr><tr><td>08/13/2020</td><td>41</td><td>LETTER RESPONSE in Opposition by USA as to Ghislaine Maxwell addressed to
Judge Alison J. Nathan from Alex Rossmiller dated August 13, 2020 re: 38 LETTER
MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell dated
August 10, 2020 re: Discovery Disclosure and Access .. (Rossmiller, Alex) (Entered:
08/13/2020)</td></tr><tr><td>08/17/2020</td><td>42</td><td>LETTER REPLY TO RESPONSE to Motion by Ghislaine Maxwell addressed to
Judge Alison J. Nathan from Christian R. Everdell dated August 17, 2020 re 38
LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated August 10, 2020 re: Discovery Disclosure and Access.. (Everdell, Christian)
(Entered: 08/17/2020)</td></tr><tr><td>08/17/2020</td><td>43</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Jeffrey S. Pagliuca
dated August 17, 2020 re: Request for Permission to Submit Letter Motion in Excess
of Three Pages. Document filed by Ghislaine Maxwell. (Pagliuca, Jeffrey) (Entered:
08/17/2020)</td></tr><tr><td>08/18/2020</td><td>44</td><td>ORDER as to Ghislaine Maxwell: On August 17, 2020, the Defendant filed a letter
motion seeking a modification of this Court's Protective Order, which the Court
entered on July 30, 2020. Defendant also moves to file that letter motion under seal.
The Governments opposition to Defendant's letter motion is hereby due Friday, August</td></tr></table>

# Case 21-58, Document 20-2, 03/24/2021, 3065965, Page11 of 24

<table><tr><th></th><th></th><th>21 at 12 p.m. The Defendant's reply is due on Monday, August 24 at 12 p.m. The
parties shall propose redactions to the letter briefing on this issue. Alternatively, the
parties shall provide support and argument for why the letter motions should be sealed
in their entirety. SO ORDERED. (Responses due by 8/21/2020. Replies due by
8/24/2020.) (Signed by Judge Alison J. Nathan on 8/18/2020) (Inl) (Entered:
08/18/2020)</th></tr><tr><td>08/20/2020</td><td>45</td><td>NOTICE OF ATTORNEY APPEARANCE Lara Elizabeth Pomerantz appearing for
USA. (Pomerantz, Lara) (Entered: 08/20/2020)</td></tr><tr><td>08/20/2020</td><td>50</td><td>SEALED DOCUMENT placed in vault. (mhe) (Entered: 08/27/2020)</td></tr><tr><td>08/21/2020</td><td>46</td><td>LETTER RESPONSE in Opposition by USA as to Ghislaine Maxwell addressed to
Judge Alison J. Nathan from Maurene Comey dated August 21, 2020 re: 43 LETTER
MOTION addressed to Judge Alison J. Nathan from Jeffrey S. Pagliuca dated August
17, 2020 re: Request for Permission to Submit Letter Motion in Excess of Three Pages
.. (Rossmiller, Alex) (Entered: 08/21/2020)</td></tr><tr><td>08/21/2020</td><td>47</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
Maurene Comey dated August 21, 2020 re: Proposed redactions to letter briefing, in
response to the Court's Order of August 18, 2020 Document filed by USA.
(Rossmiller, Alex) (Entered: 08/21/2020)</td></tr><tr><td>08/24/2020</td><td>48</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Laura A. Menninger
dated August 24, 2020 re: Request to File Under Seal: Proposed Redactions to Request
to Modify Protective Order and Reply in Support Thereof. Document filed by
Ghislaine Maxwell. (Menninger, Laura) (Entered: 08/24/2020)</td></tr><tr><td>08/25/2020</td><td>49</td><td>MEMORANDUM OPINION AND ORDER: denying without prejudice 38 LETTER
MOTION as to Ghislaine Maxwell (1). On August 10, 2020, the Defendant filed a
letter motion related to two issues. Dkt. No. 38. First, the Defendant seeks an order
directing the Government to disclose to defense counsel immediately the identities of
the three alleged victims referenced in the indictment. Second, the Defendant seeks an
order directing the Bureau of Prisons ("BOP") to release the Defendant into the general
population and to provide her with increased access to the discovery materials. For the
reasons that follow, Defendant's requests are DENIED without prejudice.... [See this
Memorandum Opinion And Order]... III. Conclusion: For the reasons stated above,
Defendant's requests contained in Dkt. No. 38 are DENIED without prejudice.
Following the close of discovery, the parties shall meet and confer on an appropriate
schedule for pre-trial disclosures, including the disclosure of § 3500 material, exhibit
lists, and witness lists, taking into account all relevant factors. The Government is
hereby ORDERED to submit written status updates every 90 days detailing any
material changes to the conditions of Ms. Maxwell's confinement, with particular
emphasis on her access to legal materials and ability to communicate with defense
counsel. SO ORDERED. (Signed by Judge Alison J. Nathan on 8/25/2020) (bw)
(Entered: 08/25/2020)</td></tr><tr><td>09/02/2020</td><td>51</td><td>MEMORANDUMOPINION AND ORDER as to Ghislaine Maxwell: On August 17,
2020, Defendant Ghislaine Maxwell filed a sealed letter motion seeking an Order
modifying the protective order in this case. Specifically, she sought a Court order
allowing her to file under seal in certain civil cases ("Civil Cases") materials
("Documents") that she received in discovery from the Government in this case. She
also sought permission to reference, but not file, other discovery material that the
Government produced in this case. For the reasons that follow, Defendant's requests
are DENIED. SO ORDERED. (Signed by Judge Alison J. Nathan on 9/2/2020)(See
MEMORANDUM OPINION AND ORDER as set forth) (Inl) (Entered: 09/02/2020)</td></tr><tr><td>09/02/2020</td><td>52</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan, from Jeffrey S.
Pagliuca dated 8/17/2020 re: Defense counsel writes with redacted request to modify
protective order. (ap) (Entered: 09/02/2020)</td></tr><tr><td>09/04/2020</td><td>55</td><td>NOTICE OF APPEAL by Ghislaine Maxwell from 51 Memorandum &amp; Opinion.
Filing fee $ 505.00, receipt number 465401266036. (tp) (Entered: 09/09/2020)</td></tr><tr><td>09/08/2020</td><td>53</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan dated 8/24/2020
re: Proposed Redactions to Request to Modify Protective Order. (jbo) (Entered:
09/08/2020)</td></tr></table>

# Case 21-58, Document 20-2, 03/24/2021, 3065965, Page12 of 24

<table><tr><th>09/08/2020</th><th>54</th><th>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan dated 8/24/2020
re: Reply in Support of Request to Modify Protective Order. (jbo) (Entered:
09/08/2020)</th></tr><tr><td>09/09/2020</td><td></td><td>Transmission of Notice of Appeal and Certified Copy of Docket Sheet as to Ghislaine
Maxwell to US Court of Appeals re: 55 Notice of Appeal. (tp) (Entered: 09/09/2020)</td></tr><tr><td>09/09/2020</td><td></td><td>Appeal Record Sent to USCA (Electronic File). Certified Indexed record on Appeal
Electronic Files as to Ghislaine Maxwell re: 55 Notice of Appeal were transmitted to
the U.S. Court of Appeals. (tp) (Entered: 09/09/2020)</td></tr><tr><td>09/10/2020</td><td>56</td><td>SEALED DOCUMENT placed in vault. (dn) (Entered: 09/11/2020)</td></tr><tr><td>09/10/2020</td><td>57</td><td>SEALED DOCUMENT placed in vault. (dn) (Entered: 09/11/2020)</td></tr><tr><td>09/24/2020</td><td>58</td><td>SEALED DOCUMENT placed in vault. (mhe) (Entered: 09/24/2020)</td></tr><tr><td>10/05/2020</td><td>59</td><td>NOTICE OF ATTORNEY APPEARANCE: Bobbi C Sternheim appearing for
Ghislaine Maxwell. Appearance Type: Retained. (Sternheim, Bobbi) (Entered:
10/05/2020)</td></tr><tr><td>10/06/2020</td><td>60</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated October 6, 2020 re:
Request to Delay Disclosure Document filed by USA. (Comey, Maurene) (Entered:
10/06/2020)</td></tr><tr><td>10/06/2020</td><td>61</td><td>AFFIDAVIT of Maurene Comey by USA as to Ghislaine Maxwell. (Comey, Maurene)
(Entered: 10/06/2020)</td></tr><tr><td>10/07/2020</td><td>62</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 60 Accordingly, the
Government respectfully requests that the Court approve the Government's request to
delay disclosure of these Materials...ENDORSEMENT...The Defendant shall file any
opposition to the Government's request by October 14, 2020. The Government's reply,
if any, is due by October 20, 2020. SO ORDERED. (Government Replies due by
10/20/2020., Defendant Responses due by 10/14/2020) (Signed by Judge Alison J.
Nathan on 10/7/20)(jw) (Entered: 10/07/2020)</td></tr><tr><td>10/07/2020</td><td>63</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAs Maurene Comey, Alison Moe, and Lara Pomerantz dated October 7, 2020 re:
Review of Investigative Files from Other Offices and Agencies Document filed by
USA. (Comey, Maurene) (Entered: 10/07/2020)</td></tr><tr><td>10/14/2020</td><td>64</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated October 14, 2020 re: Response to 60 LETTER addressed to Judge
Alison J. Nathan from USA dated October 6, 2020 re: Request to Delay Disclosure.
(Everdell, Christian) (Entered: 10/14/2020)</td></tr><tr><td>10/20/2020</td><td>65</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated October 20, 2020 re:
Reply Letter in Further Support of Request to Delay Disclosure Document filed by
USA. (Comey, Maurene) (Entered: 10/20/2020)</td></tr><tr><td>10/23/2020</td><td>66</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Jeffrey S.
Pagliuca dated October 23, 2020 re: Response to the Governments October 7, 2020
letter (Pagliuca, Jeffrey) (Entered: 10/23/2020)</td></tr><tr><td>10/30/2020</td><td>67</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAs Maurene Comey, Alison Moe, and Lara Pomerantz dated October 30, 2020 re:
Reply to Defense's October 23, 2020 Letter Document filed by USA. (Comey,
Maurene) (Entered: 10/30/2020)</td></tr><tr><td>11/05/2020</td><td>68</td><td>ORDER as to Ghislaine Maxwell: This Order is entered, pursuant to Federal Rule of
Criminal Procedure 5(f) and the Due Process Protections Act, Pub. L. No 116182, 134
Stat. 894 (Oct. 21, 2020), to confirm the Government's disclosure obligations under
Brady v. Maryland, 373 U.S. 83 (1963), and its progeny, and to summarize the
possible consequences of violating those obligations. (Signed by Judge Alison J.
Nathan on 11/5/2020) (See ORDER set forth) (ap) (Entered: 11/05/2020)</td></tr></table>

# Case 21-58, Document 20-2, 03/24/2021, 3065965, Page13 of 24

<table><tr><th>11/06/2020</th><th>69</th><th>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated November 6, 2020
re: Request to Extend Discovery Deadline for Portion of Electronic Discovery
Document filed by USA. (Comey, Maurene) (Entered: 11/06/2020)</th></tr><tr><td>11/06/2020</td><td>70</td><td>AFFIDAVIT of Maurene Comey by USA as to Ghislaine Maxwell. (Comey, Maurene)
(Entered: 11/06/2020)</td></tr><tr><td>11/09/2020</td><td>71</td><td>MANDATE of USCA (Certified Copy) as to Ghislaine Maxwell re: 55 Notice of
Appeal. USCA Case Number 20-3061-cr. UPON DUE CONSIDERATION
WHEREOF, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that the
motion to consolidate is DENIED and the appeal is DISMISSED for want of
jurisdiction.. Catherine O'Hagan Wolfe, Clerk USCA for the Second Circuit. Issued As
Mandate: 11/09/2020. (nd) (Entered: 11/09/2020)</td></tr><tr><td>11/09/2020</td><td>72</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on 69 LETTER by USA as to
Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene
Comey, Alison Moe, and Lara Pomerantz dated November 6, 2020 re: Request to
Extend Discovery Deadline for Portion of Electronic Discovery. ENDORSEMENT:
The Court hereby extends the deadline for the Government's production of electronic
discovery from November 9, 2020 to November 23, 2020. The Court also grants the
parties' request for an extension of the motions deadlines as follows: the Defendant's
motions are due by January 11, 2021, the Government's responses are due by February
12, 2021, and any replies are due by February 19, 2021. SO ORDERED. (Discovery
due by 11/23/2020. Motions due by 1/11/2021. Responses due by 2/12/2021. Replies
due by 2/19/2021.) (Signed by Judge Alison J. Nathan on 11/9/2020) (Inl) (Entered:
11/10/2020)</td></tr><tr><td>11/18/2020</td><td>73</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 60 Letter filed by USA as
to Ghislaine Maxwell re: The Government respectfully requests that the Court approve
the Government's request to delay disclosure of these
Materials...ENDORSEMENT...There is no dispute that the materials referenced in the
Government's letter will be turned over to the defense. The Government has indicated
that it will do so. The only dispute, then, relates to the timing of such disclosure. See
Dkt. Nos. 64, 65. Because the Government has articulated plausible reasons for some
delay of disclosure, see Dkt. No. 65 at 4, the Court grants the Government's request to
delay disclosure. However, the Governments proposal to delay disclosure until 8
weeks in advance of trial is insufficient. In order to ensure that the defense can
adequately prepare for trial, the Government shall produce the referenced materials,
which are not voluminous, to the defense by March 12, 2021. Disclosure of the
materials will of course be subject to the protective order entered by the Court, see
Dkt. No. 36. (Government Responses due by 3/12/2021) (Signed by Judge Alison J.
Nathan on 11/18/20)(jw) (Entered: 11/18/2020)</td></tr><tr><td>11/23/2020</td><td>74</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated November 23, 2020
re: Update Regarding Conditions of Confinement Document filed by USA. (Comey,
Maurene) (Entered: 11/23/2020)</td></tr><tr><td>11/24/2020</td><td>75</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C.
Sternheim dated 11/24/2020 re: Response to 90-day MDC conditions report
(Sternheim, Bobbi) (Entered: 11/24/2020)</td></tr><tr><td>11/24/2020</td><td>76</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 75 LETTER by Ghislaine
Maxwell addressed to Judge Alison J. Nathan from Bobbi C. Sternheim dated
11/24/2020 re: Response to 90-day MDC conditions report. ENDORSEMENT: The
parties are hereby ORDERED to meet and confer regarding Defendant's request that
Warden Heriberto Tellez directly address Defendant's concerns regarding the
conditions of her detention. The parties shall jointly submit a status update within one
week of this Order. (Signed by Judge Alison J. Nathan on 11/24/2020) (ap) (Entered:
11/24/2020)</td></tr><tr><td>12/01/2020</td><td>77</td><td>ORDER as to Ghislaine Maxwell. On November 25, 2020, the Defendant filed a letter
request under seal. On November 30, 2020, she filed a second letter request in which
she proposed redactions on both letters. The Government is hereby ORDERED to
respond to the Defendant's November 25, 2020 letter request and to the request for
proposed redactions by no later than December 2, 2020. The letters shall be</td></tr></table>

# Case 21-58, Document 20-2, 03/24/2021, 3065965, Page14 of 24

<table><tr><th></th><th></th><th>temporarily sealed while the Court resolves the redaction request. SO ORDERED.
(Signed by Judge Alison J. Nathan on 12/1/2020)(bw) (Entered: 12/01/2020)</th></tr><tr><td>12/01/2020</td><td>78</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated December 1, 2020
re: Joint Letter regarding Conditions of Confinement Document filed by USA.
(Pomerantz, Lara) (Entered: 12/01/2020)</td></tr><tr><td>12/02/2020</td><td>79</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 78 LETTER by USA
addressed to Judge Alison J. Nathan from AUSAS Maurene Comey, Alison Moe, and
Lara Pomerantz dated December 1, 2020 re: Joint Letter regarding Conditions of
Confinement. ENDORSEMENT: MDC legal counsel shall submit their letter to the
Court by December 4, 2020. Upon review of that letter, the Court will determine
whether any additional information is required, either orally or in writing. SO
ORDERED. (Signed by Judge Alison J. Nathan on 12/2/2020)(bw) (Entered:
12/02/2020)</td></tr><tr><td>12/02/2020</td><td>80</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated December 2, 2020
re: Defense Requests for Sealing Document filed by USA. (Comey, Maurene)
(Entered: 12/02/2020)</td></tr><tr><td>12/03/2020</td><td>81</td><td>ORDER as to Ghislaine Maxwell. On November 25, 2020, counsel for Defendant
Ghislaine Maxwell filed a letter request seeking an in camera conference for the
presentation of a renewed motion for release on bail and a request to seal the
November 25, 2020 letter in its entirety. The Court required justification for the
sealing request. On November 30, 2020, the defense counsel filed a second letter no
longer fully pressing the unsupported request to file the letter entirely under seal and
instead proposing redactions to both the November 25th and November 30th letters.
The Government has indicated that it does not oppose the redactions. Dkt. No. 80.
After due consideration, the Court will adopt the Defendant's proposed redactions,
which are consented to by the Government. The Court's decision is guided by the
three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of
Onondaga, 435 F.3d 110 (2d Cir. 2006). Under this test, the Court must: (i) determine
whether the documents in question are "judicial documents;" (ii) assess the weight of
the common law presumption of access to the materials; and (iii) balance competing
considerations against the presumption of access. Id. at 11920. "Such countervailing
factors include but are not limited to 'the danger of impairing law enforcement or
judicial efficiency' and 'the privacy interests of those resisting disclosure."" Id. at 120
(quoting United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995) ("Amodeo II")).
The proposed redactions satisfy this test. First, the Court finds that the Defendant's
letter motions are "relevant to the performance of the judicial function and useful in
the judicial process," thereby qualifying as a "judicial document" for purposes of the
first element of the Lugosch test. United States v. Amodeo ("Amodeo I"), 44 F.3d 141,
145 (2d Cir. 1995). And while the Court assumes that the common law presumption of
access attaches, in balancing competing considerations against the presumption of
access, the Court finds that the arguments the Defendant has put forthincluding, most
notably, the privacy interests of the individuals referenced in the lettersfavor her
proposed and tailored redactions. The Defendant is hereby ORDERED to docket the
redacted versions of the two letters by December 4, 2020. For the reasons outlined in
the Government's letter dated December 2, 2020, Dkt. No. 80, the Court DENIES the
Defendant's request for an in camera conference. In order to protect the privacy
interests referenced in the Defendant's November 25, 2020 letter, the Court will permit
the Defendant to make her submission in writing and to propose narrowly tailored
redactions. The parties are hereby ORDERED to meet and confer and to jointly
prepare a briefing schedule for the Defendant's forthcoming renewed motion for
release on bail. SO ORDERED. (Signed by Judge Alison J. Nathan on 12/3/2020)(bw)
(Entered: 12/03/2020)</td></tr><tr><td>12/03/2020</td><td>82</td><td>SEALED DOCUMENT placed in vault. (jus) (Entered: 12/03/2020)</td></tr><tr><td>12/03/2020</td><td>83</td><td>SEALED DOCUMENT placed in vault. (jus) (Entered: 12/03/2020)</td></tr><tr><td>12/03/2020</td><td>84</td><td>SEALED DOCUMENT placed in vault. (jus) (Entered: 12/03/2020)</td></tr></table>

# Case 21-58, Document 20-2, 03/24/2021, 3065965, Page15 of 24

<table><tr><th>12/04/2020</th><th>85</th><th>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated December 4, 2020 re: Briefing Schedule (Everdell, Christian) (Entered:
12/04/2020)</th></tr><tr><td>12/04/2020</td><td>86</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated 11/25/2020 re: Sealing (Everdell, Christian) (Entered: 12/04/2020)</td></tr><tr><td>12/04/2020</td><td>87</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
| Everdell dated 11/30/2020 re: Sealing (Everdell, Christian) (Entered: 12/04/2020)</td></tr><tr><td>12/07/2020</td><td>88</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Sophia
Papapetru and John Wallace dated 12/4/20 re: This letter is written in response to your
order dated December 2, 2020, concerning Ghislaine Maxwell, Reg. 02879-509., an
inmate currently confined at the Metropolitan Detention center in Brooklyn, New
York. You expressed various concerns regarding Ms. Maxwells confinement and
well-being. (jw) (Entered: 12/07/2020)</td></tr><tr><td>12/07/2020</td><td>89</td><td>ORDER as to Ghislaine Maxwell re: 85 Letter filed by Ghislaine Maxwell. The Court
is in receipt of the Defendant's December 4, 2020 letter, Dkt. No. 85, and hereby sets
the following schedule: The Defendants submission is due December 8, 2020; The
Government's response is due December 16, 2020; The Defendant's reply is due
December 18, 2020. After reviewing these submissions, the Court will determine
whether a hearing on the renewed bail motion is necessary. The Court grants the
Defendants request that the Government shall file its submission under seal with
proposed redactions. Any objections to proposed redactions are due within 24 hours
after any brief has been filed. Finally, the Defendant is granted leave to file a motion
not to exceed 40 pages. The Governments response shall also be limited to 40 pages.
The Defendant's reply shall not exceed 10 pages (Defendant submission due by
12/8/2020., Defendant Replies due by 12/18/2020., Government Responses due by
12/16/2020) (Signed by Judge Alison J. Nathan on 12/7/20)(jw) (Entered: 12/07/2020)</td></tr><tr><td>12/07/2020</td><td>90</td><td>ENDORSED LETTER as to Ghislaine Maxwell addressed to Judge Alison J. Nathan
from Mark S. Cohen and Christian R. Everdell dated 11/25/20 re: On behalf of my
client, Ghislaine Maxwell, we plan to file a Renewed Motion for Release on Bail (the
"Motion") and respectfully request an in camera conference, with all counsel present,
to address the appropriate procedures for the filing and consideration of the Motion.
For the reasons explained below, we intend to request, pursuant to Fed. R. Crim. P.
49.1(d), that the Court permit the filing of portions of the Motion and certain
supporting materials under seal and require that any responsive materials be filed
under seal....ENDORSEMENT: The Court sees no basis for the sealing of this letter.
On or before December 2, 2020, Defendant shall justify why this letter should be
sealed (or redacted). Alternatively, the Defendant may file the letter on the public
docket by that date. The Court will take no action on the request pending resolution of
the initial sealing question. The Defendant's letter and this memorandum endorsement
will be temporarily sealed pending resolution of the sealing request. (Signed by Judge
Alison J. Nathan on 11/25/20)(jw) (Entered: 12/07/2020)</td></tr><tr><td>12/07/2020</td><td>91</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C.
Sternheim dated 12/07/2020 re: Response to MDC Report to Court re: conditions
(Sternheim, Bobbi) (Entered: 12/07/2020)</td></tr><tr><td>12/08/2020</td><td>92</td><td>ORDER as to Ghislaine Maxwell: On December 4, 2020, the Court received a letter
from MDC legal counsel responding to the concerns that the Defendant raised in her
November 24, 2020 letter. See Dkt. Nos. 75, 88; see also Dkt. No. 78. The Defendant
responded to the MDC legal counsel's letter on December 7, 2020, reiterating her
request that the Court summon Warden Heriberto Tellez to personally respond to
questions from the Court regarding the Defendant's conditions of confinement. See
Dkt. No. 91. Having carefully reviewed the parties' submissions, along with the MDC
legal counsel's December 4, 2020 letter, the Court DENIES the Defendant's request to
summon the Warden to personally appear and respond to questions. This resolves Dkt.
No. 75. Notwithstanding this, as originally provided in Dkt. No. 49, the Government
shall continue to submit written status updates detailing any material changes to the
conditions of Ms. Maxwell's confinement, with particular emphasis on her access to
legal materials, including legal mail and email, and her ability to communicate with
defense counsel. The updates shall also include information on the frequency of
searches of the Defendant. The Court hereby ORDERS the Government to submit
these written updates every 60 days. Furthermore, the Government shall take all</td></tr></table>

# Case 21-58, Document 20-2, 03/24/2021, 3065965, Page16 of 24

<table><tr><th></th><th></th><th>necessary steps to ensure that the Defendant continues to receive adequate access to
her legal materials and her ability to communicate with defense counsel. (Signed by
Judge Alison J. Nathan on 12/8/2020) (ap) (Entered: 12/08/2020)</th></tr><tr><td>12/10/2020</td><td>93</td><td>TRANSCRIPT of Proceedings as to Ghislaine Maxwell re: Conference held on
7/14/2020 before Judge Alison J. Nathan. Court Reporter/Transcriber: Kristen
Carannante, (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 12/31/2020. Redacted Transcript Deadline set for 1/11/2021. Release of
Transcript Restriction set for 3/10/2021. (McGuirk, Kelly) (Entered: 12/10/2020)</td></tr><tr><td>12/10/2020</td><td>94</td><td>NOTICE OF FILING OF OFFICIAL TRANSCRIPT as to Ghislaine Maxwell. Notice
is hereby given that an official transcript of a Conference proceeding held on
7/14/2020 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.... (McGuirk, Kelly) (Entered: 12/10/2020)</td></tr><tr><td>12/14/2020</td><td>95</td><td>ORDER as to Ghislaine Maxwell: On December 8, 2020, Defendant Ghislaine
Maxwell filed her renewed application for bail under seal with proposed redactions, in
accordance with this Court's December 7, 2020 Order, see Dkt. No. 89. The
Government did not file any opposition to the Defendant's proposed redactions. After
due consideration, the Court will adopt the Defendant's proposed redactions. The
Court's decision to adopt those redactions is guided by the three-part test articulated
by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir.
2006). Under this test, the Court must: (i) determine whether the documents in
question are "judicial documents;" (ii) assess the weight of the common law
presumption of access to the materials; and (iii) balance competing considerations
against the presumption of access. Id. at 11920. "Such countervailing factors include
but are not limited to the danger of impairing law enforcement or judicial efficiency'
and 'the privacy interests of those resisting disclosure." Id. at 120 (quoting United
States v. Amodeo, 71 F.3d 1044, 1048 (2d Cir. 1995) ("Amodeo II")). The proposed
redactions satisfy this test. The Court finds that Defendant's letter motions are
"relevant to the performance of the judicial function and useful in the judicial process,'
thereby qualifying as a "judicial document" for purposes of the first element of the
Lugosch test. United States v. Amodeo ("Amodeo I"), 44 F.3d 141, 145 (2d Cir. 1995).
And the Court also finds that the common law presumption of access attaches. Id. at
146; see also Nixon v. Warner Comme'ns, Inc., 435 U.S. 589, 602 (1978).
Nevertheless, in balancing competing considerations against the presumption of
access, the Court finds that the redactions are narrowly tailored to properly guard the
privacy interests of the individuals referenced in the Defendant's submission and in the
corresponding exhibits The Defendant is hereby ORDERED to docket the redacted
documents and corresponding exhibits. (Signed by Judge Alison J. Nathan on
12/14/2020) (ap) (Entered: 12/14/2020)</td></tr><tr><td>12/14/2020</td><td>96</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated December 8, 2020 re: Cover Letter for Renewed Bail Application
(Everdell, Christian) (Entered: 12/14/2020)</td></tr><tr><td>12/14/2020</td><td>97</td><td>MEMORANDUM OF LAW in Support by Ghislaine Maxwell re: Renewed Motion
for Bail. (Attachments: # 1 Exhibit A, #2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5
Exhibit E, #6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, #2 Exhibit I, # 10 Exhibit J, #
11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16
Exhibit P, #17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit
U, #22 Exhibit V, # 23 Exhibit W, # 24 Exhibit X)(Everdell, Christian) (Entered:
12/14/2020)</td></tr><tr><td>12/17/2020</td><td>98</td><td>NOTICE OF ATTORNEY APPEARANCE Andrew Rohrbach appearing for USA.
(Rohrbach, Andrew) (Entered: 12/17/2020)</td></tr><tr><td>12/18/2020</td><td>99</td><td>ORDER as to Ghislaine Maxwell: On December 16, 2020, the Government filed its
opposition to Defendant Ghislaine Maxwell's renewed application for bail. In
accordance with this Court's December 7, 2020 Order, see Dkt. No. 89, the
Government filed its materials under seal and proposed narrowly tailored redactions on</td></tr></table>

# Case 21-58, Document 20-2, 03/24/2021, 3065965, Page17 of 24

<table><tr><th></th><th></th><th>those materials. The Defendant did not file any opposition to the Government's
proposed redactions. The Court will adopt the Government's proposed redactions after
applying the three-part test articulated by the Second Circuit in Lugosch v. Pyramid
Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Under this test, the Court must: (i)
determine whether the documents in question are "judicial documents;" (ii) assess the
weight of the common law presumption access to the materials; and (iii) balance
competing considerations against the presumption of access. Id. at 11920. "Such
countervailing factors include but are not limited to 'the danger of impairing law
enforcement or judicial efficiency' and 'the privacy interests of those resisting
disclosure."" Id. at 120 (quoting United States v. Amodeo ("Amodeo II"), 71 F.3d
1044, 1050 (2d Cir. 1995)). The proposed redactions satisfy this test. The Court finds
that the Governments submissions are "relevant to the performance of the judicial
function and useful in the judicial process," thereby qualifying as a "judicial
document" for purposes of the first element of the Lugosch test. United States v.
Amodeo ("Amodeo I"), 44 F.3d 141, 145 (2d Cir. 1995). And the Court also finds that
the common law presumption of access attaches. Id. at 146; see also Nixon v. Warner
Comme'ns, Inc., 435 U.S. 589, 602 (1978). Nevertheless, the proposed redactions are
narrowly tailored to serve substantial interests, including, most importantly, third
parties' personal privacy interests. See Under Seal v. Under Seal, 273 F. Supp. 3d 460
467 (S.D.N.Y.2017). The Government is hereby ORDERED to docket the redacted
documents and corresponding exhibits by no later than December 18, 2 (Signed by
Judge Alison J. Nathan on 12/18/2020) (ap) (Entered: 12/18/2020)</th></tr><tr><td>12/18/2020</td><td>100</td><td>MEMORANDUM OF LAW in Opposition by USA as to Ghislaine Maxwell Renewed
Bail Motion. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Comey, Maurene) (Entered:
12/18/2020)</td></tr><tr><td>12/23/2020</td><td>101</td><td>ORDER as to Ghislaine Maxwell: On December 18, 2020, the Defendant filed her
reply to the Government's opposition to her renewed application for bail. In
accordance with this Court's December 7, 2020 Order, see Dkt. No. 89, she filed these
materials under seal and proposed narrowly tailored redactions on those materials. The
Government did not file any opposition to the Defendant's proposed redactions. The
Court will adopt the Defendant's proposed redactions after applying the three-part test
articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d
110 (2d Cir. 2006). Under this test, the Court must: (i) determine whether the
documents in question are "judicial documents;" (ii) assess the weight of the common
law presumption of access to the materials; and (iii) balance competing considerations
against the presumption of access. Id. at 11920. "Such countervailing factors include
but are not limited to 'the danger of impairing law enforcement or judicial efficiency'
and 'the privacy interests of those resisting disclosure." Id. at 120 (quoting United
States v. Amodeo ("Amodeo II"), 71 F.3d 1044, 1050 (2d Cir. 1995)). The proposed
redactions satisfy this test. The Court finds that the Defendant's submissions are
"relevant to the performance of the judicial function and useful in the judicial process,'
thereby qualifying as a "judicial document" for purposes of the first element of the
Lugosch test. United States v. Amodeo ("Amodeo Î"), 44 F.3d 141, 145 (2d Cir. 1995).
And the Court also finds that the common law presumption of access attaches. Id. at
146; see also Nixon v. Warner Comme'ns, Inc., 435 U.S. 589, 602 (1978). As with the
redactions to her renewed motion for bail, the proposed redactions here are narrowly
tailored to serve substantial interests, including, most importantly, third parties
personal privacy interests. See Under Seal v. Under Seal, 273 F. Supp. 3d 460, 467
|(S.D.N.Y. 2017). See also Dkt. No. 95. The Defendant is hereby ORDERED to docket
the redacted documents and corresponding exhibits by no later than December 23,
2020. SO ORDERED. (Signed by Judge Alison J. Nathan on 12/23/2020) (Inl)
(Entered: 12/23/2020)</td></tr><tr><td>12/23/2020</td><td>102</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated December 18, 2020 re: Cover Letter for Reply Memorandum for
Renewed Bail Application (Everdell, Christian) (Entered: 12/23/2020)</td></tr><tr><td>12/23/2020</td><td>103</td><td>REPLY MEMORANDUM OF LAW in Support by Ghislaine Maxwell re: Renewed
Motion for Bail. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Everdell, Christian)
(Entered: 12/23/2020)</td></tr><tr><td>12/28/2020</td><td>104</td><td>ORDER as to Ghislaine Maxwell. On December 8, 2020, Defendant Ghislaine
Maxwell filed a renewed motion for releaseon bail. Dkt No. 97. In an Opinion and
Order concurrently filed under temporary seal, the Court DENIES the Defendant's</td></tr></table>

# Case 21-58, Document 20-2, 03/24/2021, 3065965, Page18 of 24

<table><tr><th></th><th></th><th>motion. In light of the fact that the Opinion includes potentially confidential
information that should not be filed on the public docket, the Court will permit the
parties 48 hours to propose any redactions to the Courts Opinion and Order and to
justify those redactions by reference tothe Second Circuits decision in Lugosch v.
Pyramid Co. of Onondaga, 435 F.3d 110(2d Cir. 2006). After determining which, if
any, portions of the Opinion and Order should be redacted, the Court will file the
Opinion and Order on the public docket. As a result, the Court concludes that the
Government has met its burden of persuasion that the Defendant poses a flight risk and
that pretrial detention continues to be warranted. On or before December 30, 2020, the
parties are ORDERED to submit a joint letter indicating whether they propose any
redactions and the justification for any such proposal. This resolves Dkt No. 97.
(Signed by Judge Alison J. Nathan on 12/28/20)(jw) (Entered: 12/28/2020)</th></tr><tr><td>12/30/2020</td><td>105</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated December 30, 2020
re: Joint Letter re December 28, 2020 Opinion and Order Document filed by USA.
(Comey, Maurene) (Entered: 12/30/2020)</td></tr><tr><td>12/30/2020</td><td>106</td><td>OPINION AND ORDER as to Ghislaine Maxwell. Defendant Ghislaine Maxwell has
been indicted by a grand jury on charges of conspiracy to entice minors to travel to
engage in illegal sex acts, in violation of 18 U.S.C. § 371; enticing a minor to travel to
engage in illegal sex acts, in violation of 18 U.S.C. §§ 2422 and 2; conspiracy to
transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371;
transporting minors to participate in illegal sex acts, in violation of 18 U.S.C. §§ 2423
and 2; and two charges of perjury, in violation of 18 U.S.C. § 1623. The Court held a
lengthy bail hearing on July 14, 2020. After extensive briefing and argument at the
hearing, the Court concluded that the Defendant was a clear risk of flight and that no
conditions or combination of conditions would ensure her appearance. Defendant
Ghislaine Maxwells renewed motion for release on bail, Dkt. No. 97, is DENIED.
(Signed by Judge Alison J. Nathan on 12/28/20)(jw) (Entered: 12/30/2020)</td></tr><tr><td>12/31/2020</td><td>107</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated December 31, 2020 re: Extension of Time Document filed by Ghislaine
Maxwell. (Everdell, Christian) (Entered: 12/31/2020)</td></tr><tr><td>01/05/2021</td><td>108</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell (1) on 107 LETTER MOTION
addressed to Judge Alison J. Nathan from Christian R. Everdell dated December 31,
2020 re: Extension of Time. ENDORSEMENT: SO ORDERED. (Signed by Judge
Alison J. Nathan on 1/5/2021) (ap) (Entered: 01/05/2021)</td></tr><tr><td>01/05/2021</td><td></td><td>Set/Reset Deadlines as to Ghislaine Maxwell: Motions due by 1/25/2021. Responses
due by 2/26/2021. Replies due by 3/5/2021. (ap) (Entered: 01/05/2021)</td></tr><tr><td>01/08/2021</td><td>109</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated January 8, 2021 re: Extension of Time to File Notice of Appeal. Document filed
by Ghislaine Maxwell. (Everdell, Christian) (Entered: 01/08/2021)</td></tr><tr><td>01/11/2021</td><td>110</td><td>SEALED DOCUMENT placed in vault. (jus) (Entered: 01/11/2021)</td></tr><tr><td>01/11/2021</td><td>111</td><td>SEALED DOCUMENT placed in vault. (jus) (Entered: 01/11/2021)</td></tr><tr><td>01/11/2021</td><td>112</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell (1) denying 109 LETTER
MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell dated
January 8, 2021 re: Extension of Time to File Notice of Appeal. ENDORSEMENT:
The request is denied. Good cause for an extension of time to file a notice of appeal
has not been provided. SO ORDERED. (Signed by Judge Alison J. Nathan on
1/11/2021) (Inl) (Entered: 01/11/2021)</td></tr><tr><td>01/11/2021</td><td>113</td><td>NOTICE OF APPEAL by Ghislaine Maxwell from 104 Order. (nd) (Entered:
01/12/2021)</td></tr><tr><td>01/11/2021</td><td></td><td>Appeal Remark as to re: 113 Notice of Appeal by Ghislaine Maxwell. $505.00 Appeal
filing fee due. (nd) (Entered: 01/12/2021)</td></tr><tr><td>01/12/2021</td><td></td><td>Transmission of Notice of Appeal and Certified Copy of Docket Sheet as to Ghislaine
Maxwell to US Court of Appeals re: 113 Notice of Appeal. (nd) (Entered: 01/12/2021)</td></tr></table>

# Case 21-58, Document 20-2, 03/24/2021, 3065965, Page19 of 24

<table><tr><th>01/12/2021</th><th></th><th>Appeal Record Sent to USCA (Electronic File). Certified Indexed record on Appeal
Electronic Files as to Ghislaine Maxwell re: 113 Notice of Appeal were transmitted to
the U.S. Court of Appeals. (nd) (Entered: 01/12/2021)</th></tr><tr><td>01/13/2021</td><td>114</td><td>INTERNET CITATION NOTE as to Ghislaine Maxwell: Material from decision with
Internet citation re: 106 Memorandum &amp; Opinion. (sjo) (Entered: 01/13/2021)</td></tr><tr><td>01/14/2021</td><td>115</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated January 14, 2021 re: Laptop Access (Everdell, Christian) (Entered:
01/14/2021)</td></tr><tr><td>01/15/2021</td><td>116</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on 115 LETTER by Ghislaine
Maxwell addressed to Judge Alison J. Nathan from Christian R. Everdell dated
|January 14, 2021 re: Laptop Access. ENDORSEMENT: The unobjected-to request is
GRANTED. The Bureau of Prisons is ORDERED to give the Defendant access to the
laptop computer on weekends and holidays during the hours that she is permitted to
review discovery. SO ORDERED. (Signed by Judge Alison J. Nathan on 1/15/2021)
(Inl) (Entered: 01/15/2021)</td></tr><tr><td>01/15/2021</td><td></td><td>USCA Case Number 21-0058 from the U.S. Court of Appeals, 2nd Circ. as to
Ghislaine Maxwell, assigned to 113 Notice of Appeal filed by Ghislaine Maxwell. (nd)
(Entered: 01/15/2021)</td></tr><tr><td>01/15/2021</td><td></td><td>USCA Appeal Fees received $ 505.00, receipt number 465401271727 as to Ghislaine
Maxwell on 01/15/2021 re: 113 Notice of Appeal filed by Ghislaine Maxwell. (nd)
(Entered: 01/15/2021)</td></tr><tr><td>01/25/2021</td><td>117</td><td>ORDER as to Ghislaine Maxwell: On January 25, 2021, the Court received by email
the attached letter from the Bureau of Prisons ("BOP"). In the letter, the BOP requests
that the Court vacate its January 15, 2021 Order, Dkt. No. 116, which directed the
BOP to give the Defendant access to her Government provided laptop computer on
weekends and holidays during the hours that she is permitted to review discovery. The
Defendant and the Government may respond to the BOP's letter within one week of
this Order. (Signed by Judge Alison J. Nathan on 1/25/2021) (ap) (Entered:
01/25/2021)</td></tr><tr><td>01/25/2021</td><td>118</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Mark S.
Cohen dated January 25, 2021 re: Pretrial Motions (Cohen, Mark) (Entered:
01/25/2021)</td></tr><tr><td>01/25/2021</td><td>119</td><td>MOTION for Separate Trial on Counts Ghislaine Maxwell (1) Count 5s-6s,5-6.
Document filed by Ghislaine Maxwell. (Pagliuca, Jeffrey) (Entered: 01/25/2021)</td></tr><tr><td>01/25/2021</td><td>120</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 119 MOTION for Separate
Trial on Counts Ghislaine Maxwell (1) Count 5s-6s,5-6 .. (Pagliuca, Jeffrey)
|(Entered: 01/25/2021)</td></tr><tr><td>01/25/2021</td><td>121</td><td>MOTION to Dismiss Either Count One Or Count Three of the Superseding Indictment
as Multiplicitous. Document filed by Ghislaine Maxwell. (Pagliuca, Jeffrey) (Entered:
01/25/2021)</td></tr><tr><td>01/25/2021</td><td>122</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 121 MOTION to Dismiss
Either Count One Or Count Three of the Superseding Indictment as Multiplicitous..
(Pagliuca, Jeffrey) (Entered: 01/25/2021)</td></tr><tr><td>01/25/2021</td><td>123</td><td>MOTION to Dismiss Counts One through Four of the Superseding Indictment for
Lack of Specificity. Document filed by Ghislaine Maxwell. (Pagliuca, Jeffrey)
(Entered: 01/25/2021)</td></tr><tr><td>01/25/2021</td><td>124</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 123 MOTION to Dismiss
Counts One through Four of the Superseding Indictment for Lack of Specificity..
(Pagliuca, Jeffrey) (Entered: 01/25/2021)</td></tr><tr><td>01/25/2021</td><td>125</td><td>MOTION to Dismiss the Superseding Indictment as it was Obtained in Violation of
the Sixth Amendment. Document filed by Ghislaine Maxwell. (Cohen, Mark) (Entered:
01/25/2021)</td></tr><tr><td>01/25/2021</td><td>126</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 125 MOTION to Dismiss the
Superseding Indictment as it was Obtained in Violation of the Sixth Amendment..</td></tr></table>

# Case 21-58, Document 20-2, 03/24/2021, 3065965, Page20 of 24

<table><tr><th></th><th></th><th>(Cohen, Mark) (Entered: 01/25/2021)</th></tr><tr><td>01/26/2021</td><td>127</td><td>ORDER as to Ghislaine Maxwell: On January 25, 2021, the Defendant filed twelve
pre-trial motions. Because there is a request to redact sensitive or confidential
information, several of the motions have been filed under temporary seal. The
Government may respond to the Defendant's proposed redactions within two days of
this Order. (Signed by Judge Alison J. Nathan on 1/26/2021) (ap) (Entered:
01/26/2021)</td></tr><tr><td>01/28/2021</td><td>128</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated
January 28, 2021 re: Defendant's Proposed Redactions to Pre-Trial Motions
|Document filed by USA. (Pomerantz, Lara) (Entered: 01/28/2021)</td></tr><tr><td>02/01/2021</td><td>129</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAs Maurene Comey, Alison Moe, and Lara Pomerantz dated February 1, 2021 re:
MDC Laptop Access Document filed by USA. (Comey, Maurene) (Entered:
02/01/2021)</td></tr><tr><td>02/01/2021</td><td>130</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C.
Sternheim dated 02/02/2021 re: Opposition to MDC letter (Sternheim, Bobbi)
(Entered: 02/01/2021)</td></tr><tr><td>02/02/2021</td><td>131</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on Letter addressed to Judge
Alison J. Nathan from Sophia Papapetru (Staff Attorney, MDC Brooklyn, Federal
Bureau of Prisons) dated January 25, 2021. ENDORSEMENT: Having considered the
request submitted by the Bureau of Prisons ("BOP") that the Court vacate its January
15, 2021 Order, Dkt. No. 117, as well as the Government's and the Defendant's
responses, Dkt. Nos. 129, 130, the Court hereby DENIES the BOP's request to vacate
the Order. SO ORDERED. (Signed by Judge Alison J. Nathan on 2/2/2021)(bw)
(Entered: 02/02/2021)</td></tr><tr><td>02/04/2021</td><td>132</td><td>ORDER as to Ghislaine Maxwell: The Defendant is hereby ORDERED to docket the
redacted documents and corresponding exhibits by no later than February 5, 2021.
With respect to Motion 3, the Defendant is ORDERED to docket the version that
includes the Government's proposed redactions in addition to her own. SO
ORDERED. (Signed by Judge Alison J. Nathan on 2/4/2021)(See ORDER as set forth)
(Inl) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>133</td><td>MOTION to Suppress Under the Due Process Clause All Evidence Obtained from the
Governments Subpoena to REDACTED and to Dismiss Counts Five and Six.
Document filed by Ghislaine Maxwell. (Pagliuca, Jeffrey) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>134</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 133 MOTION to Suppress
Under the Due Process Clause All Evidence Obtained from the Governments
Subpoena to REDACTED and to Dismiss Counts Five and Six.. (Attachments: # 1
Exhibit A, #2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, #1
Exhibit G, #8 Exhibit H, #2 Exhibit I)(Pagliuca, Jeffrey) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>135</td><td>MOTION to Dismiss Counts Five and Six of the Superseding Indictment Because the
Alleged Misstatements are Not Perjurious as a Matter of Law. Document filed by
| Ghislaine Maxwell. (Pagliuca, Jeffrey) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>136</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 135 MOTION to Dismiss
Counts Five and Six of the Superseding Indictment Because the Alleged Misstatements
are Not Perjurious as a Matter of Law.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, #
3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H,
#2 Exhibit I, # 10 Exhibit J, # 11 Exhibit K)(Pagliuca, Jeffrey) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>137</td><td>MOTION to Dismiss Counts One Through Six of the Superseding Indictment for
Pre-Indictment Delay. Document filed by Ghislaine Maxwell. (Pagliuca, Jeffrey)
(Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>138</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 137 MOTION to Dismiss
Counts One Through Six of the Superseding Indictment for Pre-Indictment Delay..
(Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Pagliuca,
Jeffrey) (Entered: 02/04/2021)</td></tr></table>

# Case 21-58, Document 20-2, 03/24/2021, 3065965, Page21 of 24

<table><tr><th>02/04/2021</th><th>139</th><th>MOTION to Suppress Under the Fourth Amendment, Martindell, and the Fifth
Amendment All Evidence Obtained from the Governments Subpoena to REDACTED
and to Dismiss Counts Five And Six. Document filed by Ghislaine Maxwell. (Pagliuca,
Jeffrey) (Entered: 02/04/2021)</th></tr><tr><td>02/04/2021</td><td>140</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 139 MOTION to Suppress
Under the Fourth Amendment, Martindell, and the Fifth Amendment All Evidence
Obtained from the Governments Subpoena to REDACTED and to Dismiss Counts Five
And Six.. (Pagliuca, Jeffrey) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>141</td><td>MOTION to Dismiss the Superseding Indictment for Breach of Non-Prosecution
Agreement. Document filed by Ghislaine Maxwell. (Cohen, Mark) (Entered:
02/04/2021)</td></tr><tr><td>02/04/2021</td><td>142</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 141 MOTION to Dismiss the
Superseding Indictment for Breach of Non-Prosecution Agreement.. (Attachments: #
1 Exhibit A, #2 Exhibit B, # 3 Exhibit C (Sealed), # 4 Exhibit D (Sealed), # 5 Exhibit
E (Sealed), #6 Exhibit F (Sealed), # 7 Exhibit G (Sealed), #8 Exhibit H
(Sealed))(Cohen, Mark) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>143</td><td>MOTION to Dismiss Counts One Through Four of the Superseding Indictment as
Time-Barred. Document filed by Ghislaine Maxwell. (Cohen, Mark) (Entered:
02/04/2021)</td></tr><tr><td>02/04/2021</td><td>144</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 143 MOTION to Dismiss
Counts One Through Four of the Superseding Indictment as Time-Barred.. (Cohen,
Mark) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>145</td><td>MOTION to Strike Surplusage from Superseding Indictment. Document filed by
Ghislaine Maxwell. (Cohen, Mark) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>146</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 145 MOTION to Strike
Surplusage from Superseding Indictment.. (Cohen, Mark) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>147</td><td>MOTION for Bill of Particulars and Pretrial Disclosures. Document filed by
Ghislaine Maxwell. (Cohen, Mark) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>148</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 147 MOTION for Bill of
Particulars and Pretrial Disclosures.. (Attachments: # 1 Exhibit A, # 2 Exhibit B
(Sealed), #3 Exhibit C (Sealed), # 4 Exhibit D (Sealed), # 5 Exhibit E)(Cohen, Mark)
(Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>149</td><td>AFFIDAVIT of Bobbi C. Sternheim in Support as to Ghislaine Maxwell re 147
MOTION for Bill of Particulars and Pretrial Disclosures.. (Cohen, Mark) (Entered:
02/04/2021)</td></tr><tr><td>02/05/2021</td><td>150</td><td>SEALED DOCUMENT placed in vault. (jri) (Entered: 02/05/2021)</td></tr><tr><td>02/05/2021</td><td>151</td><td>SEALED DOCUMENT placed in vault. (jri) (Entered: 02/05/2021)</td></tr><tr><td>02/05/2021</td><td>152</td><td>SEALED DOCUMENT placed in vault. (jri) (Entered: 02/05/2021)</td></tr><tr><td>02/05/2021</td><td>153</td><td>SEALED DOCUMENT placed in vault. (jri) (Entered: 02/05/2021)</td></tr><tr><td>02/05/2021</td><td>154</td><td>SEALED DOCUMENT placed in vault. (jri) (Entered: 02/05/2021)</td></tr><tr><td>02/05/2021</td><td>155</td><td>SEALED DOCUMENT placed in vault. (jri) (Entered: 02/05/2021)</td></tr><tr><td>02/05/2021</td><td>156</td><td>SEALED DOCUMENT placed in vault. (jri) (Entered: 02/05/2021)</td></tr><tr><td>02/05/2021</td><td>157</td><td>SEALED DOCUMENT placed in vault. (jri) (Entered: 02/05/2021)</td></tr><tr><td>02/05/2021</td><td>158</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated February 5, 2021 re:
MDC Conditions Update Document filed by USA. (Comey, Maurene) (Entered:
02/05/2021)</td></tr><tr><td>02/16/2021</td><td>159</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C.
Sternheim dated 02/16/2021 re: Conditions of Pretrial Confinement (Sternheim,
Bobbi) (Entered: 02/16/2021)</td></tr></table>

# Case 21-58, Document 20-2, 03/24/2021, 3065965, Page22 of 24

<table><tr><th>02/23/2021</th><th>160</th><th>THIRD MOTION for Bond. Document filed by Ghislaine Maxwell. (Sternheim,
Bobbi) (Entered: 02/23/2021)</th></tr><tr><td>02/24/2021</td><td>161</td><td>ORDER as to Ghislaine Maxwell: On February 23, 2021, Defendant Ghislaine
Maxwell filed a third motion for release on bail. Dkt. No. 160. The Government's
response is due March 9, 2021, and the Defendants reply is due March 16, 2021. SO
ORDERED. (Responses due by 3/9/2021. Replies due by 3/16/2021.) (Signed by
Judge Alison J. Nathan on 2/24/2021) (Inl) (Entered: 02/24/2021)</td></tr><tr><td>02/26/2021</td><td>162</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated
February 26, 2021 re: Cover Letter for Government Opposition to Defense Pretrial
Motions Document filed by USA. (Comey, Maurene) (Entered: 02/26/2021)</td></tr><tr><td>03/01/2021</td><td>163</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated March 1, 2021 re: Extension of Time to File Reply to Government Opposition to
Defense Pretrial Motions. Document filed by Ghislaine Maxwell. (Everdell, Christian)
(Entered: 03/01/2021)</td></tr><tr><td>03/01/2021</td><td>164</td><td>MEMO ENDORSEMENT 163 LETTER MOTION To request a 10-day extension of
time until Monday, March 15, 2021 to file our reply re: 163 LETTER MOTION
addressed to Judge Alison J. Nathan from Christian R. Everdell dated March 1, 2021
re: Extension of Time to File Briefing Schedule...ENDORSEMENT... The Defendant's
request is GRANTED. Her reply to the Government's Omnibus Memorandum in
Opposition to the Defendants Pretrial Motions is now due on March 15, 2021. SO
ORDERED. (Signed by Judge Alison J. Nathan on 3/1/21) (jw) (Entered: 03/01/2021)</td></tr><tr><td>03/01/2021</td><td></td><td>Set/Reset Deadlines/Hearings as to Ghislaine Maxwell: Defendant Replies due by
3/15/2021 (jw) (Entered: 03/01/2021)</td></tr><tr><td>03/09/2021</td><td>165</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAs Maurene Comey, Alison Moe, and Lara Pomerantz dated March 9, 2021 re:
Opposition to Third Bail Motion Document filed by USA. (Attachments: # 1 Exhibit
A)(Pomerantz, Lara) (Entered: 03/09/2021)</td></tr><tr><td>03/15/2021</td><td>166</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated March 15, 2021 re: Pretrial Motion Replies (Everdell, Christian)
(Entered: 03/15/2021)</td></tr><tr><td>03/16/2021</td><td>167</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C.
Sternheim dated 03/16/2021 re: Letter regarding Reply to Bail Motion (Sternheim,
Bobbi) (Entered: 03/16/2021)</td></tr><tr><td>03/18/2021</td><td>168</td><td>ORDER as to Ghislaine Maxwell. On February 26, 2021, the Government filed its
omnibus memorandum of law opposing Defendants' twelve pretrial motions. It filed
the brief, along with the corresponding exhibits, under temporary seal pending the
Court's resolution of its request to redact sensitive or confidential information. See
Dkt. No. 162. On March 9, 2021, the Defendant objected to certain of the redactions
that the Government had proposed, and she proposed additional redactions. Having
considered the parties' respective positions, the Court will grant the Government's
requests for redactions and sealing, as well as the Defendant's additional redaction
requests, with the exceptions discussed below. Finally, the Court denies the
Governments request to file Exhibit 11 entirely under seal. While portions of that
transcript have been redacted, other portions are part of the public record. See Giuffre
v. Maxwell, Case No. 15-cv-7433, Dkt. No. 1212-1. In light of this, the Court sees
no basis to file the transcript entirely under seal rather than by redacting the relevant
portions. In light of the above, the Government is hereby ORDERED to either docket
on ECF their brief and the corresponding exhibits, consistent with this Order, or to file
a letter with the Court justifying more tailored redaction and sealing requests regarding
pages 1128 and 187188 and Exhibits 8 and 9 by no later than March 22, 2021. The
parties are further ORDERED to meet, confer, and jointly propose redactions to the
Defendant's cover letter objecting to the Government's proposed redactions by March
22, 2021. Finally, the parties are ORDERED to meet, confer, and propose redactions
to Exhibit 11 of the Government's submission by March 22, 2021 (Signed by Judge
Alison J. Nathan on 3/18/21)(jw) (Entered: 03/18/2021)</td></tr></table>

# Case 21-58, Document 20-2, 03/24/2021, 3065965, Page23 of 24

<table><tr><th>03/22/2021</th><th>169</th><th>ORDER as to Ghislaine Maxwell: Defendant Ghislaine Maxwell's third motion for
release on bail, Dkt. No. 160, is DENIED. The parties are ORDERED to meet and
confer and propose and justify any redactions to the Defendant's reply brief by March
24, 2021. If they conclude that redactions are unnecessary, the Defendant is
ORDERED to docket the unredacted version of the brief by March 24, 2021. (Signed
by Judge Alison J. Nathan on 3/22/2021) (See ORDER set forth) (ap) Modified on
| 3/23/2021 (ap). (Entered: 03/22/2021)</th></tr><tr><td>03/22/2021</td><td>170</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated
March 22, 2021 re: Redactions to Government Opposition to Defense Pretrial Motions
Document filed by USA. (Pomerantz, Lara) (Entered: 03/22/2021)</td></tr><tr><td>03/23/2021</td><td>171</td><td>REPLY MEMORANDUM OF LAW in Support as to Ghislaine Maxwell re: 160
THIRD MOTION for Bond. . (Sternheim, Bobbi) (Entered: 03/23/2021)</td></tr><tr><td>03/24/2021</td><td>172</td><td>ORDER as to Ghislaine Maxwell. On March 5, 2021, Defendant Ghislaine Maxwell
submitted to the Court an application for an order authorizing a subpoena pursuant to
Rule 17(c)(3) of the Federal Rules of Criminal Procedure. The proposed subpoena was
directed at a law firm that represents alleged victims of the Defendant. As is standard
for Rule 17(c) subpoenas, the application was made ex parte and under seal on the
ground that it reveals defense strategy.... [*** See this Order ***]... Rule 17(c)(3)
provides that "[a]fter [an indictment] is filed, a subpoena requiring the production of
personal or confidential information about a victim may be served on a third party only
by court order," but "before entering the order and unless there are exceptional
circumstances, the court must require giving notice to the victim so that the victim can
move to quash or modify the subpoena or otherwise object." Fed. R. Crim. P. 17(c)(3).
Consistent with the Rule, on March 12, 2021, in a sealed ex parte Order, the Court
required defense counsel to provide notice to alleged victims whose personal or
confidential information may be disclosed by the proposed subpoena. The Court also
gave the alleged victims an opportunity to object to or request modifications of the
subpoena as required by Rule 17(c)(3). On March 19, 2021, the Court received a letter
from the law firm indicating that it can provide notice to alleged victims whose
personal or confidential information may be elicited by the subpoena. The law firm
shall provide notice to any such alleged victims it represents. In that letter, the law firm
also interposed substantial objections on behalf of the law firm and the alleged victims
it represents. Those objections are functionally the equivalent of a motion to quash,
even though the subpoena has not yet issued. So that the Court can receive adversarial
briefing on the proposed subpoena comparable to a motion to quash, the law firm shall
enter an appearance and file its objections on the public docket. See United States v.
Ray, No. 20-CR-110 (LJL), 2020 WL 6939677, at *10 (S.D.N.Y. Nov. 25, 2020)
("[I]f the Court determines that the subpoena calls for personal or confidential
information about a victim, it requires the requesting party have given notice to the
victim before it permits the service of the subpoena. If the victim objects, the Court
will then determine whether to modify or quash the subpoena, including on grounds
that Nixon was not satisfied."). In advance of noticing an appearance and filing, the
law firm shall meet and confer with defense counsel to see if any issues can be
narrowed before formal briefing. Moreover, prior to filing, the law firm shall confer
with defense counsel as to any proposed, necessary, and tailored redactions to the
objections. The law firm's objections with any proposed redactions shall be filed on or
before March 26, 2021. Any redactions must be justified consistent with Lugosch v.
Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Within one week of the filing
of objections, defense counsel may respond to the subpoena objections. The law firm
may reply within three days of the Defendant's response. (See Citation 1 on this Order).
Counsel shall confer regarding any proposed redactions for all briefing. SO
ORDERED. (Signed by Judge Alison J. Nathan on 3/24/2021)(bw) (Entered:
03/24/2021)</td></tr><tr><td>03/24/2021</td><td>173</td><td>NOTICE OF APPEAL by Ghislaine Maxwell from 169 Order, Terminate Motions.
(tp) (Entered: 03/24/2021)</td></tr><tr><td>03/24/2021</td><td></td><td>Appeal Remark as to Ghislaine Maxwell re: 173 Notice of Appeal. $505.00 Appeal
Fee Due. (tp) (Entered: 03/24/2021)</td></tr><tr><td>03/24/2021</td><td></td><td>Transmission of Notice of Appeal and Certified Copy of Docket Sheet as to Ghislaine
Maxwell to US Court of Appeals re: 173 Notice of Appeal. (tp) (Entered: 03/24/2021)</td></tr></table>

# Case 21-58, Document 20-2, 03/24/2021, 3065965, Page24 of 24

<table><tr><th>03/24/2021</th><th></th><th>Appeal Record Sent to USCA (Electronic File). Certified Indexed record on Appeal
Electronic Files as to Ghislaine Maxwell re: 173 Notice of Appeal were transmitted to
the U.S. Court of Appeals. (tp) (Entered: 03/24/2021)</th></tr><tr><td>03/24/2021</td><td>174</td><td>SEALED DOCUMENT placed in vault. (dn) (Entered: 03/24/2021)</td></tr><tr><td>03/24/2021</td><td>175</td><td>SEALED DOCUMENT placed in vault. (dn) (Entered: 03/24/2021)</td></tr><tr><td>03/24/2021</td><td>176</td><td>SEALED DOCUMENT placed in vault. (dn) (Entered: 03/24/2021)</td></tr></table>

Case 21-58, Document 21-1, 03/24/2021, 3065978, Page1 of 1

# United States Court of Appeals for the Second Circuit Thurgood Marshall U.S. Courthouse 40 Foley Square New York, NY 10007

DEBRA ANN LIVINGSTON
CHIEF JUDGE

CATHERINE O'HAGAN WOLFE
CLERK OF COURT

Date: March 29, 2021 Docket #: 21-770 Short Title: United States of America v. Maxwell

DC Docket #: 1:20-cr-330-1
DC Court: SDNY (NEW YORK
CITY)
DC Judge: Nathan

# NOTICE OF RECORD ON APPEAL FILED

In the above referenced case the document indicated below has been filed in the Court.

	- Record on Appeal - Certified List

	- Record on Appeal - CD ROM

	- Record on Appeal - Paper Documents

- X Record on Appeal - Electronic Index

	- Record on Appeal - Paper Index

Inquiries regarding this case may be directed to 212-857-8577.

# NOTICE OF RECORD ON APPEAL FILED (cont.)

Case 21-58, Document 21-2, 03/24/2021, 3065978, Page1 of 25

From: NYSD ECF Pool@nysd.uscourts.gov

To: NYSD CourtMail

Subject: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Appeal Record Sent to USCA - Electronic File Date: Wednesday, March 24, 2021 11:31:59 AM

This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. ***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.

## U.S. District Court

Southern District of New York

# NOTICE OF RECORD ON APPEAL FILED (cont.)

## Notice of Electronic Filing

The following transaction was entered on 3/24/2021 at 11:30 AM EDT and filed on 3/24/2021

Case Name: USA v. Maxwell
Case Number: 1:20-cr-00330-AJN
Filer:
Document Number: No document attached

Docket Text: Appeal Record Sent to USCA (Electronic File). Certified Indexed record on Appeal Electronic Files as to Ghislaine Maxwell re: [173] Notice of Appeal were transmitted to the U.S. Court of Appeals. (tp)

1:20-cr-00330-AJN-1 Notice has been electronically mailed to:

Jeffrey S. Pagliuca jpagliuca@hmflaw.com, nsimmons@hmflaw.com

Laura A. Menninger lmenninger@hmflaw.com, alundberg@hmflaw.com,
hrogers@hmflaw.com, nsimmons@hmflaw.com

Bobbi C Sternheim bc@sternheimlaw.com, bcsternheim@mac.com,
ecf@sternheimlaw.com

Christian R. Everdell ceverdell@cohengresser.com, autodocket@cohengresser.com

Mark Stewart Cohen mcohen@cohengresser.com, Mark-Cohen-1234@ecf.pacerpro.com,
autodocket@cohengresser.com, managingclerksoffice@cohengresser.com

Lara Elizabeth Pomerantz Lara.Pomerantz@usdoj.gov, CaseView.ECF@usdoj.gov,
USANYS.ECF@USDOJ.GOV

# Case 21-58, Document 21-2, 03/24/2021, 3065978, Page2 of 25

Alison Gainfort Moe alison.moe@usdoj.gov, CaseView.ECF@usdoj.gov,
USANYS.ECF@USDOJ.GOV

Alex Rossmiller alexander.rossmiller@usdoj.gov, CaseView.ECF@usdoj.gov,
USANYS.ECF@USDOJ.GOV

Maurene Ryan Comey maurene.comey@usdoj.gov, CaseView.ECF@usdoj.gov,
USANYS.ECF@USDOJ.GOV

Andrew Rohrbach Andrew.Rohrbach@usdoj.gov, caseview.ecf@usdoj.gov,
usanys.ecf@usdoj.gov

1:20-cr-00330-AJN-1 Notice has been delivered by other means to:

Case 21-58, Document 21-2, 03/24/2021, 3065978, Page3 of 25

APPEAL,ECF, INTAPP

# U.S. District Court Southern District of New York (Foley Square) CRIMINAL DOCKET FOR CASE #: 1:20-cr-00330-AJN All Defendants

Case title: USA v. Maxwell

Date Filed: 06/29/2020

Assigned to: Judge Alison J.
Nathan

Appeals court case number:
21-0058 U.S. Court of Appeals,
2nd Circ.

# U.S. District Court Southern District of New York (Foley Square) CRIMINAL DOCKET FOR CASE #: 1:20-cr-00330-AJN All Defendants (cont.)

## Defendant (1)

Ghislaine Maxwell
also known as
Sealed Defendant 1

represented by Christian R. Everdell
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
212-707-7268
Fax: 212-957-4514
Email: ceverdell@cohengresser.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Jeffrey S. Pagliuca
Haddon Morgan and Foreman
150 East 10th Avenue
Denver, CO 80203
(303)-831-7364
Fax: (303)-832-2628
Email: ipagliuca@hmflaw.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Laura A. Menninger
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
(303)-831-7364
Fax: (303)-832-2628
Email: lmenninger@hmflaw.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Mark Stewart Cohen
Cohen & Gresser, LLP (NYC)
800 Third Avenue
New York, NY 10022
(212) 957-7600
Fax: (212)957-4514
Email: mcohen@cohengresser.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Bobbi C Sternheim
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
(212) 243-1100
Fax: (888) 587-4737
Email: bc@sternheimlaw.com

# Case 21-58, Document 21-2, 03/24/2021, 3065978, Page4 of 25

ATTORNEY TO BE NOTICED

Pending Counts

Disposition

18:371.F CONSPIRACY TO
ENTICE MINORS TO TRAVEL
TO ENGAGE IN ILLEGAL SEX
ACTS
(1)

18:371.F CONSPIRACY TO
ENTICE MINORS TO TRAVEL
TO ENGAGE IN ILLEGAL SEX
ACTS
(1s)

18:2422.F COERCION OR
ENTICEMENT OFA MINOT TO
TRAVEL TO ENGAGE IN
ILLEGAL SEX ACTS
(2)

18:2422.F COERCION OR
ENTICEMENT OF MINOR TO
ENGAGE IN ILLEGAL SEX
ACTS
(2s)

18:371.F CONSPIRACY TO
TRANSPORT MINORS WITH
INTENT TO ENGAGE IN
CRIMINAL SEXUAL ACTIVITY
(3)

18:371.F 18:371.F CONSPIRACY
TO TRANSPORT MINORS WITH
INTENT TO ENGAGE IN
CRIMINAL SEXUAL ACTIVITY
(3s)

18:2423.F COERCION OR
ENTICEMENT OF MINOR
FEMALE (TRANSPORTATION
OF A MINOR WITH INTENT TO
ENGAGE IN CRIMINAL
SEXUAL ACTIVITY)
(4)

18:2423.F TRANSPORTATION
OF A MINOR WITH INTENT TO
ENGAGE IN CRIMINAL
SEXUAL ACTIVITY
(4s)

18:1623.F FALSE
DECLARATIONS BEFORE
GRAND JURY/COURT
(PERJURY)
(5-6)

18:1623.F FALSE
DECLARATIONS BEFORE
GRAND JURY/COURT
(5s-6s)

## Highest Offense Level (Opening)

Felony

# Case 21-58, Document 21-2, 03/24/2021, 3065978, Page5 of 25

Terminated Counts

None

- Highest Offense Level
(Terminated)

None

Complaints
None

Plaintiff

USA

Disposition

Disposition

represented by Alex Rossmiller
U.S. Attorney's Office, Southern District of
New York
1 St. Andrew's Plaza
New York, NY 10007
(212) 637-2415
Email: alexander.rossmiller@usdoj.gov
LEAD ATTORNEY
PRO HAC VICE
ATTORNEY TO BE NOTICED
Designation: Assistant US Attorney

Alison Gainfort Moe
United States Attorney's Office, SDNY
One Saint Andrew's Plaza
New York, NY 10007
(212) 637-2225
Email: alison.moe@usdoj.gov
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Designation: Assistant US Attorney

Maurene Ryan Comey
United States Attorney's Office, SDNY
One Saint Andrew's Plaza
New York, NY 10007
(212) 637-2324
Email: maurene.comey@usdoj.gov
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Designation: Assistant US Attorney

Andrew Rohrbach
DOJ-USAO
1 St. Andrew's Plaza
New York, NY 10007
212-637-2345
Email: Andrew.Rohrbach@usdoj.gov
ATTORNEY TO BE NOTICED

Lara Elizabeth Pomerantz
United States Attorney's Office
One St. Andrew's Plaza
New York, NY 10007
212-637-2343
Fax: 212-637-2527
Email: Lara.Pomerantz@usdoj.gov
ATTORNEY TO BE NOTICED

# Case 21-58, Document 21-2, 03/24/2021, 3065978, Page6 of 25

<table><tr><th>Date Filed</th><th>#</th><th>Docket Text</th></tr><tr><td>06/29/2020</td><td>1</td><td>SEALED INDICTMENT as to Sealed Defendant 1 (1) count(s) 1, 2, 3, 4, 5-6. (jm)
(Main Document 1 replaced on 7/2/2020) (jm). (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td>2</td><td>Order to Unseal Indictment as to Sealed Defendant 1. (Signed by Magistrate Judge
Katharine H. Parker on 7/2/20)(jm) (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td></td><td>INDICTMENT UNSEALED as to Ghislaine Maxwell. (jm) (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td></td><td>Case Designated ECF as to Ghislaine Maxwell. (jm) (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td></td><td>Case as to Ghislaine Maxwell ASSIGNED to Judge Alison J. Nathan. (jm) (Entered:
07/02/2020)</td></tr><tr><td>07/02/2020</td><td></td><td>Attorney update in case as to Ghislaine Maxwell. Attorney Alex Rossmiller, Maurene
Ryan Comey,Alison Gainfort Moe for USA added. (jm) (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td>4</td><td>MOTION to detain defendant. Document filed by USA as to Ghislaine Maxwell.
(Moe, Alison) (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td></td><td>Arrest of Ghislaine Maxwell in the United States District Court - District of New
Hampshire. (jm) (Entered: 07/06/2020)</td></tr><tr><td>07/05/2020</td><td>5</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Alex Rossmiller dated July 5, 2020 re:
Request to Schedule Initial Appearance Document filed by USA. (Comey, Maurene)
(Entered: 07/05/2020)</td></tr><tr><td>07/06/2020</td><td>6</td><td>Rule 5(c)(3) Documents Received as to Ghislaine Maxwell from the United States
District Court District of New Hampshire. (jm) (Entered: 07/06/2020)</td></tr><tr><td>07/06/2020</td><td>7</td><td>ORDER as to Ghislaine Maxwell. This matter has been assigned to me for all
purposes. In its July 5, 2020 letter, the Government on behalf of the parties requested
that the Court schedule an arraignment, initial appearance, and bail hearing in this
matter in the afternoon of Friday, July 10. See Dkt. No. 5. In light of the COVID
public health crisis, there are significant safety issues related to in-court proceedings.
If the Defendant is willing to waive her physical presence, this proceeding will be
conducted remotely. To that end, defense counsel should confer with the Defendant
regarding waiving her physical presence. If the Defendant wishes to waive her
physical presence for this proceeding, she and her counsel should sign the attached
form in advance of the proceeding if feasible. If this proceeding is to be conducted
remotely, there are protocols at the Metropolitan Detention Center that limit the times
at which the Defendant could be produced so that she could appear by video. In the
next week, the Defendant could be produced by video at either 9:00 a.m. on July 9,
2020 or sometime during the morning of July 14, 2020. Counsel are hereby ordered to
meet and confer regarding scheduling for this initial proceeding in light of these
constraints. If counsel does anticipate proceeding remotely, by 9:00 p.m. tonight,
counsel should file a joint letter proposing a date and time for the proceeding
consistent with this scheduling information, as well as a revised briefing schedule for
the Defendant's bail application.SO ORDERED. (Signed by Judge Alison J. Nathan on
7/6/2020)(jbo) (Entered: 07/06/2020)</td></tr><tr><td>07/06/2020</td><td>8</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Mark S.
Cohen dated July 6, 2020 re: Scheduling (Cohen, Mark) (Entered: 07/06/2020)</td></tr><tr><td>07/07/2020</td><td>2</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
Alex Rossmiller dated July 7, 2020 re: scheduling Document filed by USA.
(Rossmiller, Alex) (Entered: 07/07/2020)</td></tr><tr><td>07/07/2020</td><td>10</td><td>ORDER as to Ghislaine Maxwell. An arraignment, initial conference, and bail hearing
in this matter is hereby scheduled to occur as a remote video/teleconference using an
internet platform on July 14, 2020 at 1 p.m. In advance of the conference, Chambers
will email counsel with further information on how to access the video conference. To
optimize the quality of the video feed, only the Court, the Defendant, defense counsel,
and counsel for the Government will appear by video for the proceeding; all others
may access the audio of the public proceeding by telephone. Due to the limited</td></tr></table>

# Case 21-58, Document 21-2, 03/24/2021, 3065978, Page7 of 25

<table><tr><th></th><th></th><th>capacity of the internet platform system, only one attorney per party may participate
by video. Co-counsel, members of the press, and the public may access the audio feed
of the proceeding by calling a dial-in number, which the Court will provide in
advance of the proceeding by subsequent order. Given the high degree of public
interest in this case, a video feed of the remote proceeding will be available for
viewing in the Jury Assembly Room located at the Daniel Patrick Moynihan
Courthouse, 500 Pearl Street, New York, NY. Due to social distancing requirements,
seating will be extremely limited; when capacity is reached no additional persons will
be admitted. Per the S.D.N.Y. COVID-19 Courthouse Entry Program, anyone who
appears at any S.D.N.Y. courthouse must complete a questionnaire on the date of the
proceeding prior to arriving at the courthouse. All visitors must also have their
temperature taken when they arrive at the courthouse. Please see the instructions,
attached. Completing the questionnaire ahead of time will save time and effort upon
entry. Only persons who meet the entry requirements established by the questionnaire
and whose temperatures are below 100.4 degrees will be allowed to enter the
courthouse. Face coverings that cover the nose and mouth must be worn at all times.
| Anyone who fails to comply with the COVID-19 protocols that have been adopted by
the Court will be required to leave the courthouse. There are no exceptions. As
discussed in the Court's previous order, defense counsel shall, if possible, discuss the
Waiver of Right to be Present at Criminal Proceeding with the Defendant prior to the
proceeding. See Dkt. No. 7. If the Defendant consents, and is able to sign the form
(either personally or, in accordance with Standing Order 20-MC-174 of March 27,
2020, by defense counsel), defense counsel shall file the executed form at least 24
hours prior to the proceeding. In the event the Defendant consents, but counsel is
unable to obtain or affix the Defendant's signature on the form, the Court will conduct
an inquiry at the outset of the proceeding to determine whether it is appropriate for the
Court to add the Defendant's signature to the form. Pursuant to 18 U.S.C. § 3771(c)(1),
the Government must make their best efforts to see that crime victims are notified of,
and accorded, the rights provided to them in that section. This includes [t]he right to
reasonable, accurate, and timely notice of any public court proceeding... involving the
crime or of any release... of the accused and "[t]he right to be reasonably heard at any
public proceeding in the district court involving release." Id. § 3771(a)(2), (4). The
Court will inquire with the Government as to the extent of those efforts. So that
appropriate logistical arrangements can be made, the Government shall inform the
Court by email within 24 hours in advance of the proceeding if any alleged victim
wishes to be heard on the question of detention pending trial. Finally, the time between
the Defendant's arrest and July 6, 2020 is excluded under the Speedy Trial Act due to
the delay involved in transferring the Defendant from another district. See 18 U.S.C. §
3161(h)(1)(F). And the Court further excludes time under the Speedy Trial Act from
today through July 14, 2020. Due to the logistical issues involved in conducting a
remote proceeding, the Court finds "that the ends of justice served by [this exclusion]
outweigh the best interest of the public and the defendant in a speedy trial." 18 U.S.C.
§ 3161(h)(7)(A). The exclusion is also supported by the need for the parties to discuss
a potential protective order, which will facilitate the timely production of discovery in
a manner protective of the rights of third parties. See Dkt. No. 5. SO ORDERED.
(Signed by Judge Alison J. Nathan on 7/7/2020)(jbo) (Entered: 07/07/2020)</th></tr><tr><td>07/08/2020</td><td>11</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on 2 LETTER by USA as to
Ghislaine Maxwell addressed to Judge Alison J. Nathan from Alex Rossmiller dated
July 7, 2020 re: scheduling. ENDORSEMENT: The Court hereby sets the following
briefing schedule. The Defense response is due by 1:00 p.m. on July 10, 2020. The
Government reply is due by 1:00 p.m. on July 13, 2020. Additionally, defense counsel
is ordered to file notices of appearance on the docket by the end of the day today. SO
ORDERED. (Responses due by 7/10/2020. Replies due by 7/13/2020.) (Signed by
Judge Alison J. Nathan on 7/8/2020) (Inl) (Entered: 07/08/2020)</td></tr><tr><td>07/08/2020</td><td>12</td><td>NOTICE OF ATTORNEY APPEARANCE: Mark Stewart Cohen appearing for
| Ghislaine Maxwell. Appearance Type: Retained. (Cohen, Mark) (Entered: 07/08/2020)</td></tr><tr><td>07/08/2020</td><td>13</td><td>NOTICE OF ATTORNEY APPEARANCE: Christian R. Everdell appearing for
Ghislaine Maxwell. Appearance Type: Retained. (Everdell, Christian) (Entered:
07/08/2020)</td></tr><tr><td>07/08/2020</td><td>14</td><td>NOTICE OF ATTORNEY APPEARANCE: Laura A. Menninger appearing for
Ghislaine Maxwell. Appearance Type: Retained. (Menninger, Laura) (Entered:</td></tr></table>

# Case 21-58, Document 21-2, 03/24/2021, 3065978, Page8 of 25

<table><tr><th></th><th></th><th>07/08/2020)</th></tr><tr><td>07/08/2020</td><td>15</td><td>MOTION for Jeffrey S. Pagliuca to Appear Pro Hac Vice. Filing fee $ 200.00, receipt
number ANYSDC-20605229. Motion and supporting papers to be reviewed by
Clerk's Office staff. Document filed by Ghislaine Maxwell. (Attachments: # 1 Exhibit
Declaration of Jeffrey S. Pagliuca, # 2 Exhibit Certificate of Good Standing, #3 Text
of Proposed Order Proposed Order)(Pagliuca, Jeffrey) (Entered: 07/08/2020)</td></tr><tr><td>07/08/2020</td><td>17</td><td>(S1) SUPERSEDING INDICTMENT FILED as to Ghislaine Maxwell (1) count(s) 1s,
2s, 3s, 4s, 5s-6s. (jm) (Entered: 07/10/2020)</td></tr><tr><td>07/09/2020</td><td></td><td>|&gt;&gt;&gt;NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document
No. 15 MOTION for Jeffrey S. Pagliuca to Appear Pro Hac Vice. Filing fee $
200.00, receipt number ANYSDC-20605229. Motion and supporting papers to be
reviewed by Clerk's Office staff. The document has been reviewed and there are
no deficiencies. (aea) (Entered: 07/09/2020)</td></tr><tr><td>07/09/2020</td><td>16</td><td>ORDER as to Ghislaine Maxwell. As discussed in its previous order, the Court will
hold an arraignment, initial conference, and bail hearing in this matter remotely as a
video/teleconference on July 14, 2020 at 1 pm. Members of the press and the public in
the United States may access the live audio feed of the proceeding by calling
855-268-7844 and using access code 32091812# and PIN 9921299#. Those outside of
the United States may access the live audio feed by calling 214-416-0400 and using
the same access code and PIN. These phone lines can accommodate approximately
500 callers on a first come, first serve basis. The Court will provide counsel for both
sides an additional dial-in number to be used to ensure audio access to the proceeding
for non-speaking co-counsel, alleged victims, and any family members of the
Defendant. The United States Attorney's Office should email Chambers with
information regarding any alleged victims who are entitled, pursuant to 18 U.S.C.
$3771(a)(4), to be heard at the bail hearing and who wish to be heard. The Court will
then provide information as to the logistics for their dial-in access. As the Court
described in a previous order, members of the press and public may watch and listen to
the live video feed in the Jury Assembly Room, at the Daniel Patrick Moynihan
Courthouse, 500 Pearl Street. See Dkt. No. 10. However, in light of COVID-19,
seating will be limited to approximately 60 seats in order to enable appropriate social
distancing and ensure public safety. Counsel for the Defendant and the Government
may contact Chambers by email if there is a request to accommodate alleged victims
or family members of the Defendant. Members of the credentialed in-house press
corps may contact the District Executive's Office about seating. Otherwise, all seating
will be allocated on a first come, first serve basis and in accordance with the S.D.N.Y.
| COVID-19 Courthouse Entry Program and this Court's previous order of July 7, 2020.
|See Dkt. No. 10. If conditions change or the Court otherwise concludes that allowing
for in-person viewing of the video feed at the courthouse is not consistent with public
health, the Court may provide audio access by telephone only. Any photographing,
recording, or rebroadcasting of federal court proceedings is prohibited by law.
Violation of these prohibitions may result in fines or sanctions, including removal of
court issued media credentials, restricted entry to future hearings, denial of entry to
future hearings, or any other sanctions deemed necessary by the Court. SO
ORDERED. (Signed by Judge Alison J. Nathan on 7/9/2020)(jbo) (Entered:
07/09/2020)</td></tr><tr><td>07/10/2020</td><td>18</td><td>MEMORANDUM in Opposition by Ghislaine Maxwell re 4 MOTION to detain
defendant.. (Cohen, Mark) (Entered: 07/10/2020)</td></tr><tr><td>07/10/2020</td><td>19</td><td>NOTICE OF ATTORNEY APPEARANCE: Mark Stewart Cohen appearing for
| Ghislaine Maxwell. Appearance Type: Retained. (Cohen, Mark) (Entered: 07/10/2020)</td></tr><tr><td>07/10/2020</td><td>20</td><td>NOTICE OF ATTORNEY APPEARANCE: Christian R. Everdell appearing for
Ghislaine Maxwell. Appearance Type: Retained. (Everdell, Christian) (Entered:
07/10/2020)</td></tr><tr><td>07/10/2020</td><td>21</td><td>WAIVER of Personal Appearance at Arraignment and Entry of Plea of Not Guilty by
Ghislaine Maxwell. (Everdell, Christian) (Entered: 07/10/2020)</td></tr><tr><td>07/13/2020</td><td>22</td><td>REPLY MEMORANDUM OF LAW in Support by USA as to Ghislaine Maxwell re:
4 MOTION to detain defendant. . (Moe, Alison) (Entered: 07/13/2020)</td></tr></table>

# Case 21-58, Document 21-2, 03/24/2021, 3065978, Page9 of 25

<table><tr><th>07/13/2020</th><th></th><th>ORDER granting 15 Motion for Jeffrey Pagliuca to Appear Pro Hac Vice as to
Ghislaine Maxwell (1). (Signed by Judge Alison J. Nathan on 7/13/2020) (kwi)
(Entered: 07/13/2020)</th></tr><tr><td>07/14/2020</td><td>23</td><td>ORDER as to Ghislaine Maxwell. For the reasons stated on the record at today's
proceeding, the Governments motion to detain the Defendant pending trial is hereby
GRANTED (Signed by Judge Alison J. Nathan on 7/14/20)(jw) (Entered: 07/14/2020)</td></tr><tr><td>07/14/2020</td><td></td><td>Minute Entry for proceedings held before Judge Alison J. Nathan:Arraignment as to
Ghislaine Maxwell (1) Count 1s,2s,3s, 4s, 5s-6s held on 7/14/2020. Defendant
Ghislaine Maxwell present by video conference with attorney Mark Cohen present by
video conference, AUSA Alison Moe, Alex Rossmiller and Maurene Comey for the
government present by video conference, Pretrial Service Officer Lea Harmon present
by telephone and Court Reporter Kristine Caraannante. Defendant enters a plea of Not
Guilty to the S1 indictment. Trial set for July 12, 2021. See Order. Time is excluded
under the Speedy Trial Act from today until July 12, 2021. Bail is denied. Defendant is
remanded. See Transcript. (jw) (Entered: 07/14/2020)</td></tr><tr><td>07/14/2020</td><td></td><td>Minute Entry for proceedings held before Judge Alison J. Nathan: Plea entered by
Ghislaine Maxwell (1) Count 1s,2s,3s, 4s, 5s-6s Not Guilty. (jw) (Entered: 07/14/2020)</td></tr><tr><td>07/14/2020</td><td>24</td><td>Waiver of Right to be Present at Criminal Proceeding as to Ghislaine Maxwell re:
Arraignment, Bail Hearing, Conference. (jw) (Entered: 07/14/2020)</td></tr><tr><td>07/15/2020</td><td>25</td><td>ORDER as to Ghislaine Maxwell. Initial non-electronic discovery, generally to
include search warrant applications and subpoena returns, is due by Friday, August 21,
2020. Completion of discovery, to include electronic materials, is due by Monday,
November 9, 2020. Motions are due by Monday, December 21, 2020. Motion
responses are due by Friday, January 22, 2021. Motion replies are due by Friday,
February 5, 2021. Trial is set for Monday, July 12, 2021 (Discovery due by
8/21/2020., Motions due by 12/21/2020) (Signed by Judge Alison J. Nathan on
7/15/20)(jw) (Entered: 07/15/2020)</td></tr><tr><td>07/21/2020</td><td>26</td><td>ORDER as to Ghislaine Maxwell: The Court has received a significant number of
letters and messages from non-parties that purport to be related to this case. These
submissions are either procedurally improper or irrelevant to the judicial function.
Therefore, they will not be considered or docketed. The Court will accord the same
treatment to any similar correspondence it receives in the future. SO ORDERED.
(Signed by Judge Alison J. Nathan on 7/21/2020) (Inl) (Entered: 07/21/2020)</td></tr><tr><td>07/21/2020</td><td>27</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Jeffrey S. Pagliuca
dated July 21, 2020 re: Local Criminal Rule 23.1. Document filed by Ghislaine
Maxwell. (Pagliuca, Jeffrey) (Entered: 07/21/2020)</td></tr><tr><td>07/23/2020</td><td>28</td><td>ORDER as to Ghislaine Maxwell: The Defense has moved for an order "prohibiting
the Government, its agents and counsel for witnesses from making extrajudicial
statements concerning this case." Dkt. No. 27 at 1. The Court firmly expects that
counsel for all involved parties will exercise great care to ensure compliance with this
| Court's local rules, including Local Criminal Rule 23.1, and the rules of professional
responsibility. In light of this clear expectation, the Court does not believe that further
action is needed at this time to protect the Defendant's right to a fair trial by an
impartial jury. Accordingly, it denies the Defendant's motion without prejudice. But
the Court warns counsel and agents for the parties and counsel for potential witnesses
that going forward it will not hesitate to take appropriate action in the face of
| violations of any relevant rules. The Court will ensure strict compliance with those
rules and will ensure that the Defendant's right to a fair trial will be safeguarded.
(Signed by Judge Alison J. Nathan on 7/23/2020) (ap) (Entered: 07/23/2020)</td></tr><tr><td>07/27/2020</td><td>29</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated July 27, 2020 re: Proposed Protective Order. Document filed by Ghislaine
Maxwell. (Attachments: # 1 Exhibit A (Proposed Protective Order))(Everdell,
Christian) (Entered: 07/27/2020)</td></tr><tr><td>07/27/2020</td><td>30</td><td>AFFIDAVIT of Christian R. Everdell by Ghislaine Maxwell. (Everdell, Christian)
(Entered: 07/27/2020)</td></tr><tr><td>07/27/2020</td><td>31</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
Alison Moe dated July 27, 2020 re: requesting until 5 p.m. tomorrow to respond to</td></tr></table>

# Case 21-58, Document 21-2, 03/24/2021, 3065978, Page 10 of 25

<table><tr><th></th><th></th><th>defense counsel's letter, filed July 27, 2020 Document filed by USA. (Moe, Alison)
(Entered: 07/27/2020)</th></tr><tr><td>07/27/2020</td><td>32</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on 31 LETTER by USA as to
Ghislaine Maxwell addressed to Judge Alison J. Nathan from Alison Moe dated July
27, 2020 re: requesting until 5 p.m. tomorrow to respond to defense counsel's letter,
filed July 27, 2020. ENDORSEMENT: The Government's response to the Defense's
letter is due by 5 p.m. on July 28, 2020. The Defense may file a reply by 5 p.m. on
July 29, 2020. Before the Government's response is filed, the parties must meet and
confer by phone regarding this issue, and any response from the Government must
contain an affirmation that the parties have done so. SO ORDERED. (Responses due
by 7/28/2020. Replies due by 7/29/2020.) (Signed by Judge Alison J. Nathan on
7/27/2020) (Inl) (Entered: 07/27/2020)</td></tr><tr><td>07/28/2020</td><td>33</td><td>LETTER RESPONSE to Motion by USA as to Ghislaine Maxwell addressed to Judge
Alison J. Nathan from Alex Rossmiller dated July 28, 2020 re: 29 LETTER MOTION
addressed to Judge Alison J. Nathan from Christian R. Everdell dated July 27, 2020 re:
Proposed Protective Order.. (Attachments: # 1 Exhibit A (proposed protective
order))(Rossmiller, Alex) (Entered: 07/28/2020)</td></tr><tr><td>07/28/2020</td><td>34</td><td>AFFIDAVIT of Alex Rossmiller by USA as to Ghislaine Maxwell. (Rossmiller, Alex)
(Entered: 07/28/2020)</td></tr><tr><td>07/29/2020</td><td>35</td><td>LETTER REPLY TO RESPONSE to Motion by Ghislaine Maxwell addressed to
Judge Alison J. Nathan from Christian R. Everdell dated July 29, 2020 re 29 LETTER
MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell dated July
27, 2020 re: Proposed Protective Order .. (Everdell, Christian) (Entered: 07/29/2020)</td></tr><tr><td>07/30/2020</td><td>36</td><td>PROTECTIVE ORDER as to Ghislaine Maxwell...regarding procedures to be
followed that shall govern the handling of confidential material. SO ORDERED:
(Signed by Judge Alison J. Nathan on 7/30/2020)(bw) (Entered: 07/31/2020)</td></tr><tr><td>07/30/2020</td><td>37</td><td>MEMORANDUM OPINION &amp; ORDER as to Ghislaine Maxwell. Both parties have
asked for the Court to enter a protective order. While they agree on most of the
language, two areas of dispute have emerged. First, Ms. Maxwell seeks language
allowing her to publicly reference alleged victims or witnesses who have spoken on
the public record to the media or in public fora, or in litigation relating to Ms. Maxwell
or Jeffrey Epstein. Second, Ms. Maxwell seeks language restricting potential
Government witnesses and their counsel from using discovery materials for any
purpose other than preparing for the criminal trial in this action. The Government has
proposed contrary language on both of these issues. For the following reasons, the
Court adopts the Government's proposed protective order Under Federal Rule of
Criminal Procedure 16(d)(1), "[a]t any time the court may, for good cause, deny,
restrict, or defer discovery or inspection, or grant other appropriate relief." The good
cause standard "requires courts to balance several interests, including whether
dissemination of the discovery materials inflicts hazard to others... whether the
imposition of the protective order would prejudice the defendant," and "the public's
interest in the information." United States v. Smith, 985 F. Supp. 2d 506, 522
| (S.D.N.Y. 2013). The party seeking to restrict disclosure bears the burden of showing
good cause. Cf. Gambale v. Deutsche Bank AG, 377 F.3d 133, 142 (2d Cir. 2004).
First, the Court finds that the Government has met its burden of showing good cause
with regard to restricting the ability of Ms. Maxwell to publicly reference alleged
victims and witnesses other than those who have publicly identified themselves in this
litigation. As a general matter, it is undisputed that there is a strong and specific
interest in protecting the privacy of alleged victims and witnesses in this case that
supports restricting the disclosure of their identities. Dkt. No. 29 at 3 (acknowledging
that as a baseline the protective order should "prohibit[] Ms. Maxwell, defense
counsel, and others on the defense team from disclosing or disseminating the identity
of any alleged victim or potential witness referenced in the discovery materials"); see
also United States v. Corley, No. 13-cr-48, 2016 U.S. Dist. LEXIS 194426, at *11
(S.D.N.Y. Jan. 15, 2016). The Defense argues this interest is significantly diminished
for individuals who have spoken on the public record about Ms. Maxwell or Jeffrey
Epstein, because they have voluntarily chosen to identify themselves. But not all
accusations or public statements are equal. Deciding to participate in or contribute to a
| criminal investigation or prosecution is a far different matter than simply making a
public statement "relating to" Ms. Maxwell or Jeffrey Epstein, particularly since such a</td></tr></table>

# Case 21-58, Document 21-2, 03/24/2021, 3065978, Page11 of 25

<table><tr><th></th><th></th><th>statement might have occurred decades ago and have no relevance to the charges in
this case. These individuals still maintain a significant privacy interest that must be
safeguarded. The exception the Defense seeks is too broad and risks undermining the
protections of the privacy of witnesses and alleged victims that is required by law. In
contrast, the Government's proffered language would allow Ms. Maxwell to publicly
reference individuals who have spoken by name on the record in this case. It also
allows the Defense to "referenc[e] the identities of individuals they believe may be
relevant... to Potential Defense Witnesses and their counsel during the course of the
investigation and preparation of the defense case at trial." Dkt. No. 33-1, 5. This
proposal adequately balances the interests at stake. And as the Government's letter
notes, see Dkt. No. 33 at 4, to the extent that the Defense needs an exception to the
protective order for a specific investigative purpose, they can make applications to the
Court on a case-by-case basis. Second, restrictions on the ability of potential
witnesses and their counsel to use discovery materials for purposes other than
preparing for trial in this case are unwarranted. The request appears unprecedented
despite the fact that there have been many high-profile criminal matters that had
related civil litigation. The Government labors under many restrictions including Rule
6(e) of the Federal Rules of Criminal Procedure, the Privacy Act of 1974, and other
policies of the Department of Justice and the U.S. Attorney's Office for the Southern
District of New York, all of which the Court expects the Government to scrupulously
follow. Furthermore, the Government indicates that it will likely only provide potential
witnesses with materials that those witnesses already have in their possession. See Dkt.
No. 33 at 6. And of course, those witnesses who do testify at trial would be subject to
| examination on the record as to what materials were provided or shown to them by the
Government. Nothing in the Defense's papers explains how its unprecedented
proposed restriction is somehow necessary to ensure a fair trial. For the foregoing
reasons, the Court adopts the Government's proposed protective order, which will be
entered on the docket. This resolves Dkt. No. 29. SO ORDERED. (Signed by Judge
Alison J. Nathan on 7/30/2020)(bw) (Entered: 07/31/2020)</th></tr><tr><td>08/10/2020</td><td>38</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated August 10, 2020 re: Discovery Disclosure and Access. Document filed by
Ghislaine Maxwell. (Everdell, Christian) (Entered: 08/10/2020)</td></tr><tr><td>08/10/2020</td><td>39</td><td>AFFIDAVIT of Christian R. Everdell by Ghislaine Maxwell. (Everdell, Christian)
(Entered: 08/10/2020)</td></tr><tr><td>08/11/2020</td><td>40</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 38 LETTER MOTION
addressed to Judge Alison J. Nathan from Christian R. Everdell dated August 10, 2020
re: Discovery Disclosure and Access. ENDORSEMENT: The Government is hereby
ORDERED to respond to the Defendant's letter motion by Thursday, August 13, 2020.
The Defendant's reply, if any, is due on or before Monday, August 17, 2020.
(Responses due by 8/13/2020. Replies due by 8/17/2020) (Signed by Judge Alison J.
Nathan on 8/11/2020) (ap) (Entered: 08/11/2020)</td></tr><tr><td>08/13/2020</td><td>41</td><td>LETTER RESPONSE in Opposition by USA as to Ghislaine Maxwell addressed to
Judge Alison J. Nathan from Alex Rossmiller dated August 13, 2020 re: 38 LETTER
MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell dated
August 10, 2020 re: Discovery Disclosure and Access .. (Rossmiller, Alex) (Entered:
08/13/2020)</td></tr><tr><td>08/17/2020</td><td>42</td><td>LETTER REPLY TO RESPONSE to Motion by Ghislaine Maxwell addressed to
Judge Alison J. Nathan from Christian R. Everdell dated August 17, 2020 re 38
LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated August 10, 2020 re: Discovery Disclosure and Access.. (Everdell, Christian)
(Entered: 08/17/2020)</td></tr><tr><td>08/17/2020</td><td>43</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Jeffrey S. Pagliuca
dated August 17, 2020 re: Request for Permission to Submit Letter Motion in Excess
of Three Pages. Document filed by Ghislaine Maxwell. (Pagliuca, Jeffrey) (Entered:
08/17/2020)</td></tr><tr><td>08/18/2020</td><td>44</td><td>ORDER as to Ghislaine Maxwell: On August 17, 2020, the Defendant filed a letter
motion seeking a modification of this Court's Protective Order, which the Court
entered on July 30, 2020. Defendant also moves to file that letter motion under seal.
The Governments opposition to Defendant's letter motion is hereby due Friday, August</td></tr></table>

# Case 21-58, Document 21-2, 03/24/2021, 3065978, Page12 of 25

<table><tr><th></th><th></th><th>21 at 12 p.m. The Defendant's reply is due on Monday, August 24 at 12 p.m. The
parties shall propose redactions to the letter briefing on this issue. Alternatively, the
parties shall provide support and argument for why the letter motions should be sealed
in their entirety. SO ORDERED. (Responses due by 8/21/2020. Replies due by
8/24/2020.) (Signed by Judge Alison J. Nathan on 8/18/2020) (Inl) (Entered:
08/18/2020)</th></tr><tr><td>08/20/2020</td><td>45</td><td>NOTICE OF ATTORNEY APPEARANCE Lara Elizabeth Pomerantz appearing for
USA. (Pomerantz, Lara) (Entered: 08/20/2020)</td></tr><tr><td>08/20/2020</td><td>50</td><td>SEALED DOCUMENT placed in vault. (mhe) (Entered: 08/27/2020)</td></tr><tr><td>08/21/2020</td><td>46</td><td>LETTER RESPONSE in Opposition by USA as to Ghislaine Maxwell addressed to
Judge Alison J. Nathan from Maurene Comey dated August 21, 2020 re: 43 LETTER
MOTION addressed to Judge Alison J. Nathan from Jeffrey S. Pagliuca dated August
17, 2020 re: Request for Permission to Submit Letter Motion in Excess of Three Pages
.. (Rossmiller, Alex) (Entered: 08/21/2020)</td></tr><tr><td>08/21/2020</td><td>47</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
Maurene Comey dated August 21, 2020 re: Proposed redactions to letter briefing, in
response to the Court's Order of August 18, 2020 Document filed by USA.
(Rossmiller, Alex) (Entered: 08/21/2020)</td></tr><tr><td>08/24/2020</td><td>48</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Laura A. Menninger
dated August 24, 2020 re: Request to File Under Seal: Proposed Redactions to Request
to Modify Protective Order and Reply in Support Thereof. Document filed by
Ghislaine Maxwell. (Menninger, Laura) (Entered: 08/24/2020)</td></tr><tr><td>08/25/2020</td><td>49</td><td>MEMORANDUM OPINION AND ORDER: denying without prejudice 38 LETTER
MOTION as to Ghislaine Maxwell (1). On August 10, 2020, the Defendant filed a
letter motion related to two issues. Dkt. No. 38. First, the Defendant seeks an order
directing the Government to disclose to defense counsel immediately the identities of
the three alleged victims referenced in the indictment. Second, the Defendant seeks an
order directing the Bureau of Prisons ("BOP") to release the Defendant into the general
population and to provide her with increased access to the discovery materials. For the
reasons that follow, Defendant's requests are DENIED without prejudice.... [See this
Memorandum Opinion And Order]... III. Conclusion: For the reasons stated above,
Defendant's requests contained in Dkt. No. 38 are DENIED without prejudice.
Following the close of discovery, the parties shall meet and confer on an appropriate
schedule for pre-trial disclosures, including the disclosure of § 3500 material, exhibit
lists, and witness lists, taking into account all relevant factors. The Government is
hereby ORDERED to submit written status updates every 90 days detailing any
material changes to the conditions of Ms. Maxwell's confinement, with particular
emphasis on her access to legal materials and ability to communicate with defense
counsel. SO ORDERED. (Signed by Judge Alison J. Nathan on 8/25/2020) (bw)
(Entered: 08/25/2020)</td></tr><tr><td>09/02/2020</td><td>51</td><td>MEMORANDUMOPINION AND ORDER as to Ghislaine Maxwell: On August 17,
2020, Defendant Ghislaine Maxwell filed a sealed letter motion seeking an Order
modifying the protective order in this case. Specifically, she sought a Court order
allowing her to file under seal in certain civil cases ("Civil Cases") materials
("Documents") that she received in discovery from the Government in this case. She
also sought permission to reference, but not file, other discovery material that the
Government produced in this case. For the reasons that follow, Defendant's requests
are DENIED. SO ORDERED. (Signed by Judge Alison J. Nathan on 9/2/2020)(See
MEMORANDUM OPINION AND ORDER as set forth) (Inl) (Entered: 09/02/2020)</td></tr><tr><td>09/02/2020</td><td>52</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan, from Jeffrey S.
Pagliuca dated 8/17/2020 re: Defense counsel writes with redacted request to modify
protective order. (ap) (Entered: 09/02/2020)</td></tr><tr><td>09/04/2020</td><td>55</td><td>NOTICE OF APPEAL by Ghislaine Maxwell from 51 Memorandum &amp; Opinion.
Filing fee $ 505.00, receipt number 465401266036. (tp) (Entered: 09/09/2020)</td></tr><tr><td>09/08/2020</td><td>53</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan dated 8/24/2020
re: Proposed Redactions to Request to Modify Protective Order. (jbo) (Entered:
09/08/2020)</td></tr></table>

# Case 21-58, Document 21-2, 03/24/2021, 3065978, Page13 of 25

<table><tr><th>09/08/2020</th><th>54</th><th>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan dated 8/24/2020
re: Reply in Support of Request to Modify Protective Order. (jbo) (Entered:
09/08/2020)</th></tr><tr><td>09/09/2020</td><td>|</td><td>Transmission of Notice of Appeal and Certified Copy of Docket Sheet as to Ghislaine
Maxwell to US Court of Appeals re: 55 Notice of Appeal. (tp) (Entered: 09/09/2020)</td></tr><tr><td>09/09/2020</td><td></td><td>Appeal Record Sent to USCA (Electronic File). Certified Indexed record on Appeal
Electronic Files as to Ghislaine Maxwell re: 55 Notice of Appeal were transmitted to
the U.S. Court of Appeals. (tp) (Entered: 09/09/2020)</td></tr><tr><td>09/10/2020</td><td>56</td><td>SEALED DOCUMENT placed in vault. (dn) (Entered: 09/11/2020)</td></tr><tr><td>09/10/2020</td><td>57</td><td>SEALED DOCUMENT placed in vault. (dn) (Entered: 09/11/2020)</td></tr><tr><td>09/24/2020</td><td>58</td><td>SEALED DOCUMENT placed in vault. (mhe) (Entered: 09/24/2020)</td></tr><tr><td>10/05/2020</td><td>59</td><td>NOTICE OF ATTORNEY APPEARANCE: Bobbi C Sternheim appearing for
Ghislaine Maxwell. Appearance Type: Retained. (Sternheim, Bobbi) (Entered:
10/05/2020)</td></tr><tr><td>10/06/2020</td><td>60</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated October 6, 2020 re:
Request to Delay Disclosure Document filed by USA. (Comey, Maurene) (Entered:
10/06/2020)</td></tr><tr><td>10/06/2020</td><td>61</td><td>AFFIDAVIT of Maurene Comey by USA as to Ghislaine Maxwell. (Comey, Maurene)
(Entered: 10/06/2020)</td></tr><tr><td>10/07/2020</td><td>62</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 60 Accordingly, the
Government respectfully requests that the Court approve the Government's request to
delay disclosure of these Materials...ENDORSEMENT...The Defendant shall file any
opposition to the Government's request by October 14, 2020. The Government's reply,
if any, is due by October 20, 2020. SO ORDERED. (Government Replies due by
10/20/2020., Defendant Responses due by 10/14/2020) (Signed by Judge Alison J.
Nathan on 10/7/20)(jw) (Entered: 10/07/2020)</td></tr><tr><td>10/07/2020</td><td>63</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAs Maurene Comey, Alison Moe, and Lara Pomerantz dated October 7, 2020 re:
Review of Investigative Files from Other Offices and Agencies Document filed by
USA. (Comey, Maurene) (Entered: 10/07/2020)</td></tr><tr><td>10/14/2020</td><td>64</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated October 14, 2020 re: Response to 60 LETTER addressed to Judge
Alison J. Nathan from USA dated October 6, 2020 re: Request to Delay Disclosure.
(Everdell, Christian) (Entered: 10/14/2020)</td></tr><tr><td>10/20/2020</td><td>65</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated October 20, 2020 re:
Reply Letter in Further Support of Request to Delay Disclosure Document filed by
USA. (Comey, Maurene) (Entered: 10/20/2020)</td></tr><tr><td>10/23/2020</td><td>66</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Jeffrey S.
Pagliuca dated October 23, 2020 re: Response to the Governments October 7, 2020
letter (Pagliuca, Jeffrey) (Entered: 10/23/2020)</td></tr><tr><td>10/30/2020</td><td>67</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAs Maurene Comey, Alison Moe, and Lara Pomerantz dated October 30, 2020 re:
Reply to Defense's October 23, 2020 Letter Document filed by USA. (Comey,
Maurene) (Entered: 10/30/2020)</td></tr><tr><td>11/05/2020</td><td>68</td><td>ORDER as to Ghislaine Maxwell: This Order is entered, pursuant to Federal Rule of
Criminal Procedure 5(f) and the Due Process Protections Act, Pub. L. No 116182, 134
Stat. 894 (Oct. 21, 2020), to confirm the Government's disclosure obligations under
Brady v. Maryland, 373 U.S. 83 (1963), and its progeny, and to summarize the
possible consequences of violating those obligations. (Signed by Judge Alison J.
Nathan on 11/5/2020) (See ORDER set forth) (ap) (Entered: 11/05/2020)</td></tr></table>

# Case 21-58, Document 21-2, 03/24/2021, 3065978, Page14 of 25

<table><tr><th>11/06/2020</th><th>69</th><th>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated November 6, 2020
re: Request to Extend Discovery Deadline for Portion of Electronic Discovery
Document filed by USA. (Comey, Maurene) (Entered: 11/06/2020)</th></tr><tr><td>11/06/2020</td><td>70</td><td>AFFIDAVIT of Maurene Comey by USA as to Ghislaine Maxwell. (Comey, Maurene)
(Entered: 11/06/2020)</td></tr><tr><td>11/09/2020</td><td>71</td><td>MANDATE of USCA (Certified Copy) as to Ghislaine Maxwell re: 55 Notice of
Appeal. USCA Case Number 20-3061-cr. UPON DUE CONSIDERATION
WHEREOF, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that the
motion to consolidate is DENIED and the appeal is DISMISSED for want of
jurisdiction.. Catherine O'Hagan Wolfe, Clerk USCA for the Second Circuit. Issued As
Mandate: 11/09/2020. (nd) (Entered: 11/09/2020)</td></tr><tr><td>11/09/2020</td><td>72</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on 69 LETTER by USA as to
Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene
Comey, Alison Moe, and Lara Pomerantz dated November 6, 2020 re: Request to
Extend Discovery Deadline for Portion of Electronic Discovery. ENDORSEMENT:
The Court hereby extends the deadline for the Government's production of electronic
discovery from November 9, 2020 to November 23, 2020. The Court also grants the
parties' request for an extension of the motions deadlines as follows: the Defendant's
motions are due by January 11, 2021, the Government's responses are due by February
12, 2021, and any replies are due by February 19, 2021. SO ORDERED. (Discovery
due by 11/23/2020. Motions due by 1/11/2021. Responses due by 2/12/2021. Replies
due by 2/19/2021.) (Signed by Judge Alison J. Nathan on 11/9/2020) (Inl) (Entered:
11/10/2020)</td></tr><tr><td>11/18/2020</td><td>73</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 60 Letter filed by USA as
to Ghislaine Maxwell re: The Government respectfully requests that the Court approve
the Government's request to delay disclosure of these
Materials...ENDORSEMENT...There is no dispute that the materials referenced in the
Government's letter will be turned over to the defense. The Government has indicated
that it will do so. The only dispute, then, relates to the timing of such disclosure. See
Dkt. Nos. 64, 65. Because the Government has articulated plausible reasons for some
delay of disclosure, see Dkt. No. 65 at 4, the Court grants the Government's request to
delay disclosure. However, the Governments proposal to delay disclosure until 8
weeks in advance of trial is insufficient. In order to ensure that the defense can
adequately prepare for trial, the Government shall produce the referenced materials,
which are not voluminous, to the defense by March 12, 2021. Disclosure of the
materials will of course be subject to the protective order entered by the Court, see
Dkt. No. 36. (Government Responses due by 3/12/2021) (Signed by Judge Alison J.
Nathan on 11/18/20)(jw) (Entered: 11/18/2020)</td></tr><tr><td>11/23/2020</td><td>74</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated November 23, 2020
re: Update Regarding Conditions of Confinement Document filed by USA. (Comey,
Maurene) (Entered: 11/23/2020)</td></tr><tr><td>11/24/2020</td><td>75</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C.
Sternheim dated 11/24/2020 re: Response to 90-day MDC conditions report
(Sternheim, Bobbi) (Entered: 11/24/2020)</td></tr><tr><td>11/24/2020</td><td>76</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 75 LETTER by Ghislaine
Maxwell addressed to Judge Alison J. Nathan from Bobbi C. Sternheim dated
11/24/2020 re: Response to 90-day MDC conditions report. ENDORSEMENT: The
parties are hereby ORDERED to meet and confer regarding Defendant's request that
Warden Heriberto Tellez directly address Defendant's concerns regarding the
conditions of her detention. The parties shall jointly submit a status update within one
week of this Order. (Signed by Judge Alison J. Nathan on 11/24/2020) (ap) (Entered:
11/24/2020)</td></tr><tr><td>12/01/2020</td><td>77</td><td>ORDER as to Ghislaine Maxwell. On November 25, 2020, the Defendant filed a letter
request under seal. On November 30, 2020, she filed a second letter request in which
she proposed redactions on both letters. The Government is hereby ORDERED to
respond to the Defendant's November 25, 2020 letter request and to the request for
proposed redactions by no later than December 2, 2020. The letters shall be</td></tr></table>

# Case 21-58, Document 21-2, 03/24/2021, 3065978, Page15 of 25

<table><tr><th></th><th></th><th>temporarily sealed while the Court resolves the redaction request. SO ORDERED.
(Signed by Judge Alison J. Nathan on 12/1/2020)(bw) (Entered: 12/01/2020)</th></tr><tr><td>12/01/2020</td><td>78</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated December 1, 2020
re: Joint Letter regarding Conditions of Confinement Document filed by USA.
(Pomerantz, Lara) (Entered: 12/01/2020)</td></tr><tr><td>12/02/2020</td><td>79</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 78 LETTER by USA
addressed to Judge Alison J. Nathan from AUSAS Maurene Comey, Alison Moe, and
Lara Pomerantz dated December 1, 2020 re: Joint Letter regarding Conditions of
Confinement. ENDORSEMENT: MDC legal counsel shall submit their letter to the
Court by December 4, 2020. Upon review of that letter, the Court will determine
whether any additional information is required, either orally or in writing. SO
ORDERED. (Signed by Judge Alison J. Nathan on 12/2/2020)(bw) (Entered:
12/02/2020)</td></tr><tr><td>12/02/2020</td><td>80</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated December 2, 2020
re: Defense Requests for Sealing Document filed by USA. (Comey, Maurene)
(Entered: 12/02/2020)</td></tr><tr><td>12/03/2020</td><td>81</td><td>ORDER as to Ghislaine Maxwell. On November 25, 2020, counsel for Defendant
Ghislaine Maxwell filed a letter request seeking an in camera conference for the
presentation of a renewed motion for release on bail and a request to seal the
November 25, 2020 letter in its entirety. The Court required justification for the
sealing request. On November 30, 2020, the defense counsel filed a second letter no
longer fully pressing the unsupported request to file the letter entirely under seal and
instead proposing redactions to both the November 25th and November 30th letters.
The Government has indicated that it does not oppose the redactions. Dkt. No. 80.
After due consideration, the Court will adopt the Defendant's proposed redactions,
which are consented to by the Government. The Court's decision is guided by the
three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of
Onondaga, 435 F.3d 110 (2d Cir. 2006). Under this test, the Court must: (i) determine
whether the documents in question are "judicial documents;" (ii) assess the weight of
the common law presumption of access to the materials; and (iii) balance competing
considerations against the presumption of access. Id. at 11920. "Such countervailing
factors include but are not limited to 'the danger of impairing law enforcement or
judicial efficiency' and 'the privacy interests of those resisting disclosure."" Id. at 120
(quoting United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995) ("Amodeo II")).
The proposed redactions satisfy this test. First, the Court finds that the Defendant's
letter motions are "relevant to the performance of the judicial function and useful in
the judicial process," thereby qualifying as a "judicial document" for purposes of the
first element of the Lugosch test. United States v. Amodeo ("Amodeo I"), 44 F.3d 141,
145 (2d Cir. 1995). And while the Court assumes that the common law presumption of
access attaches, in balancing competing considerations against the presumption of
access, the Court finds that the arguments the Defendant has put forthincluding, most
notably, the privacy interests of the individuals referenced in the lettersfavor her
proposed and tailored redactions. The Defendant is hereby ORDERED to docket the
redacted versions of the two letters by December 4, 2020. For the reasons outlined in
the Government's letter dated December 2, 2020, Dkt. No. 80, the Court DENIES the
Defendant's request for an in camera conference. In order to protect the privacy
interests referenced in the Defendant's November 25, 2020 letter, the Court will permit
the Defendant to make her submission in writing and to propose narrowly tailored
redactions. The parties are hereby ORDERED to meet and confer and to jointly
prepare a briefing schedule for the Defendant's forthcoming renewed motion for
release on bail. SO ORDERED. (Signed by Judge Alison J. Nathan on 12/3/2020)(bw)
(Entered: 12/03/2020)</td></tr><tr><td>12/03/2020</td><td>82</td><td>SEALED DOCUMENT placed in vault. (jus) (Entered: 12/03/2020)</td></tr><tr><td>12/03/2020</td><td>83</td><td>SEALED DOCUMENT placed in vault. (jus) (Entered: 12/03/2020)</td></tr><tr><td>12/03/2020</td><td>84</td><td>SEALED DOCUMENT placed in vault. (jus) (Entered: 12/03/2020)</td></tr></table>

# Case 21-58, Document 21-2, 03/24/2021, 3065978, Page16 of 25

<table><tr><th>12/04/2020</th><th>85</th><th>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated December 4, 2020 re: Briefing Schedule (Everdell, Christian) (Entered:
12/04/2020)</th></tr><tr><td>12/04/2020</td><td>86</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated 11/25/2020 re: Sealing (Everdell, Christian) (Entered: 12/04/2020)</td></tr><tr><td>12/04/2020</td><td>87</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
| Everdell dated 11/30/2020 re: Sealing (Everdell, Christian) (Entered: 12/04/2020)</td></tr><tr><td>12/07/2020</td><td>88</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Sophia
Papapetru and John Wallace dated 12/4/20 re: This letter is written in response to your
order dated December 2, 2020, concerning Ghislaine Maxwell, Reg. 02879-509., an
inmate currently confined at the Metropolitan Detention center in Brooklyn, New
York. You expressed various concerns regarding Ms. Maxwells confinement and
well-being. (jw) (Entered: 12/07/2020)</td></tr><tr><td>12/07/2020</td><td>89</td><td>ORDER as to Ghislaine Maxwell re: 85 Letter filed by Ghislaine Maxwell. The Court
is in receipt of the Defendant's December 4, 2020 letter, Dkt. No. 85, and hereby sets
the following schedule: The Defendants submission is due December 8, 2020; The
Government's response is due December 16, 2020; The Defendant's reply is due
December 18, 2020. After reviewing these submissions, the Court will determine
whether a hearing on the renewed bail motion is necessary. The Court grants the
Defendants request that the Government shall file its submission under seal with
proposed redactions. Any objections to proposed redactions are due within 24 hours
after any brief has been filed. Finally, the Defendant is granted leave to file a motion
not to exceed 40 pages. The Governments response shall also be limited to 40 pages.
The Defendant's reply shall not exceed 10 pages (Defendant submission due by
12/8/2020., Defendant Replies due by 12/18/2020., Government Responses due by
12/16/2020) (Signed by Judge Alison J. Nathan on 12/7/20)(jw) (Entered: 12/07/2020)</td></tr><tr><td>12/07/2020</td><td>90</td><td>ENDORSED LETTER as to Ghislaine Maxwell addressed to Judge Alison J. Nathan
from Mark S. Cohen and Christian R. Everdell dated 11/25/20 re: On behalf of my
client, Ghislaine Maxwell, we plan to file a Renewed Motion for Release on Bail (the
"Motion") and respectfully request an in camera conference, with all counsel present,
to address the appropriate procedures for the filing and consideration of the Motion.
For the reasons explained below, we intend to request, pursuant to Fed. R. Crim. P.
49.1(d), that the Court permit the filing of portions of the Motion and certain
supporting materials under seal and require that any responsive materials be filed
under seal....ENDORSEMENT: The Court sees no basis for the sealing of this letter.
On or before December 2, 2020, Defendant shall justify why this letter should be
sealed (or redacted). Alternatively, the Defendant may file the letter on the public
docket by that date. The Court will take no action on the request pending resolution of
the initial sealing question. The Defendant's letter and this memorandum endorsement
will be temporarily sealed pending resolution of the sealing request. (Signed by Judge
Alison J. Nathan on 11/25/20)(jw) (Entered: 12/07/2020)</td></tr><tr><td>12/07/2020</td><td>91</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C.
Sternheim dated 12/07/2020 re: Response to MDC Report to Court re: conditions
(Sternheim, Bobbi) (Entered: 12/07/2020)</td></tr><tr><td>12/08/2020</td><td>92</td><td>ORDER as to Ghislaine Maxwell: On December 4, 2020, the Court received a letter
from MDC legal counsel responding to the concerns that the Defendant raised in her
November 24, 2020 letter. See Dkt. Nos. 75, 88; see also Dkt. No. 78. The Defendant
responded to the MDC legal counsel's letter on December 7, 2020, reiterating her
request that the Court summon Warden Heriberto Tellez to personally respond to
questions from the Court regarding the Defendant's conditions of confinement. See
Dkt. No. 91. Having carefully reviewed the parties' submissions, along with the MDC
legal counsel's December 4, 2020 letter, the Court DENIES the Defendant's request to
summon the Warden to personally appear and respond to questions. This resolves Dkt.
No. 75. Notwithstanding this, as originally provided in Dkt. No. 49, the Government
shall continue to submit written status updates detailing any material changes to the
conditions of Ms. Maxwell's confinement, with particular emphasis on her access to
legal materials, including legal mail and email, and her ability to communicate with
defense counsel. The updates shall also include information on the frequency of
searches of the Defendant. The Court hereby ORDERS the Government to submit
these written updates every 60 days. Furthermore, the Government shall take all</td></tr></table>

# Case 21-58, Document 21-2, 03/24/2021, 3065978, Page17 of 25

<table><tr><th></th><th></th><th>necessary steps to ensure that the Defendant continues to receive adequate access to
her legal materials and her ability to communicate with defense counsel. (Signed by
Judge Alison J. Nathan on 12/8/2020) (ap) (Entered: 12/08/2020)</th></tr><tr><td>12/10/2020</td><td>93</td><td>TRANSCRIPT of Proceedings as to Ghislaine Maxwell re: Conference held on
7/14/2020 before Judge Alison J. Nathan. Court Reporter/Transcriber: Kristen
Carannante, (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 12/31/2020. Redacted Transcript Deadline set for 1/11/2021. Release of
Transcript Restriction set for 3/10/2021. (McGuirk, Kelly) (Entered: 12/10/2020)</td></tr><tr><td>12/10/2020</td><td>94</td><td>NOTICE OF FILING OF OFFICIAL TRANSCRIPT as to Ghislaine Maxwell. Notice
is hereby given that an official transcript of a Conference proceeding held on
7/14/2020 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.... (McGuirk, Kelly) (Entered: 12/10/2020)</td></tr><tr><td>12/14/2020</td><td>95</td><td>ORDER as to Ghislaine Maxwell: On December 8, 2020, Defendant Ghislaine
Maxwell filed her renewed application for bail under seal with proposed redactions, in
accordance with this Court's December 7, 2020 Order, see Dkt. No. 89. The
Government did not file any opposition to the Defendant's proposed redactions. After
due consideration, the Court will adopt the Defendant's proposed redactions. The
Court's decision to adopt those redactions is guided by the three-part test articulated
by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir.
2006). Under this test, the Court must: (i) determine whether the documents in
question are "judicial documents;" (ii) assess the weight of the common law
presumption of access to the materials; and (iii) balance competing considerations
against the presumption of access. Id. at 11920. "Such countervailing factors include
but are not limited to the danger of impairing law enforcement or judicial efficiency'
and 'the privacy interests of those resisting disclosure." Id. at 120 (quoting United
States v. Amodeo, 71 F.3d 1044, 1048 (2d Cir. 1995) ("Amodeo II")). The proposed
redactions satisfy this test. The Court finds that Defendant's letter motions are
"relevant to the performance of the judicial function and useful in the judicial process,'
thereby qualifying as a "judicial document" for purposes of the first element of the
Lugosch test. United States v. Amodeo ("Amodeo I"), 44 F.3d 141, 145 (2d Cir. 1995).
And the Court also finds that the common law presumption of access attaches. Id. at
146; see also Nixon v. Warner Comme'ns, Inc., 435 U.S. 589, 602 (1978).
Nevertheless, in balancing competing considerations against the presumption of
access, the Court finds that the redactions are narrowly tailored to properly guard the
privacy interests of the individuals referenced in the Defendant's submission and in the
corresponding exhibits The Defendant is hereby ORDERED to docket the redacted
documents and corresponding exhibits. (Signed by Judge Alison J. Nathan on
12/14/2020) (ap) (Entered: 12/14/2020)</td></tr><tr><td>12/14/2020</td><td>96</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated December 8, 2020 re: Cover Letter for Renewed Bail Application
(Everdell, Christian) (Entered: 12/14/2020)</td></tr><tr><td>12/14/2020</td><td>97</td><td>MEMORANDUM OF LAW in Support by Ghislaine Maxwell re: Renewed Motion
for Bail. (Attachments: # 1 Exhibit A, #2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5
Exhibit E, #6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, #2 Exhibit I, # 10 Exhibit J, #
11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16
Exhibit P, #17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit
U, #22 Exhibit V, # 23 Exhibit W, # 24 Exhibit X)(Everdell, Christian) (Entered:
12/14/2020)</td></tr><tr><td>12/17/2020</td><td>98</td><td>NOTICE OF ATTORNEY APPEARANCE Andrew Rohrbach appearing for USA.
(Rohrbach, Andrew) (Entered: 12/17/2020)</td></tr><tr><td>12/18/2020</td><td>99</td><td>ORDER as to Ghislaine Maxwell: On December 16, 2020, the Government filed its
opposition to Defendant Ghislaine Maxwell's renewed application for bail. In
accordance with this Court's December 7, 2020 Order, see Dkt. No. 89, the
Government filed its materials under seal and proposed narrowly tailored redactions on</td></tr></table>

# Case 21-58, Document 21-2, 03/24/2021, 3065978, Page18 of 25

<table><tr><th></th><th></th><th>those materials. The Defendant did not file any opposition to the Government's
proposed redactions. The Court will adopt the Government's proposed redactions after
applying the three-part test articulated by the Second Circuit in Lugosch v. Pyramid
Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Under this test, the Court must: (i)
determine whether the documents in question are "judicial documents;" (ii) assess the
weight of the common law presumption access to the materials; and (iii) balance
competing considerations against the presumption of access. Id. at 11920. "Such
countervailing factors include but are not limited to 'the danger of impairing law
enforcement or judicial efficiency' and 'the privacy interests of those resisting
disclosure."" Id. at 120 (quoting United States v. Amodeo ("Amodeo II"), 71 F.3d
1044, 1050 (2d Cir. 1995)). The proposed redactions satisfy this test. The Court finds
that the Governments submissions are "relevant to the performance of the judicial
function and useful in the judicial process," thereby qualifying as a "judicial
document" for purposes of the first element of the Lugosch test. United States v.
Amodeo ("Amodeo I"), 44 F.3d 141, 145 (2d Cir. 1995). And the Court also finds that
the common law presumption of access attaches. Id. at 146; see also Nixon v. Warner
Comme'ns, Inc., 435 U.S. 589, 602 (1978). Nevertheless, the proposed redactions are
narrowly tailored to serve substantial interests, including, most importantly, third
parties' personal privacy interests. See Under Seal v. Under Seal, 273 F. Supp. 3d 460
467 (S.D.N.Y.2017). The Government is hereby ORDERED to docket the redacted
documents and corresponding exhibits by no later than December 18, 2 (Signed by
Judge Alison J. Nathan on 12/18/2020) (ap) (Entered: 12/18/2020)</th></tr><tr><td>12/18/2020</td><td>100</td><td>MEMORANDUM OF LAW in Opposition by USA as to Ghislaine Maxwell Renewed
Bail Motion. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Comey, Maurene) (Entered:
12/18/2020)</td></tr><tr><td>12/23/2020</td><td>101</td><td>ORDER as to Ghislaine Maxwell: On December 18, 2020, the Defendant filed her
reply to the Government's opposition to her renewed application for bail. In
accordance with this Court's December 7, 2020 Order, see Dkt. No. 89, she filed these
materials under seal and proposed narrowly tailored redactions on those materials. The
Government did not file any opposition to the Defendant's proposed redactions. The
Court will adopt the Defendant's proposed redactions after applying the three-part test
articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d
110 (2d Cir. 2006). Under this test, the Court must: (i) determine whether the
documents in question are "judicial documents;" (ii) assess the weight of the common
law presumption of access to the materials; and (iii) balance competing considerations
against the presumption of access. Id. at 11920. "Such countervailing factors include
but are not limited to 'the danger of impairing law enforcement or judicial efficiency'
and 'the privacy interests of those resisting disclosure." Id. at 120 (quoting United
States v. Amodeo ("Amodeo II"), 71 F.3d 1044, 1050 (2d Cir. 1995)). The proposed
redactions satisfy this test. The Court finds that the Defendant's submissions are
"relevant to the performance of the judicial function and useful in the judicial process,'
thereby qualifying as a "judicial document" for purposes of the first element of the
Lugosch test. United States v. Amodeo ("Amodeo Î"), 44 F.3d 141, 145 (2d Cir. 1995).
And the Court also finds that the common law presumption of access attaches. Id. at
146; see also Nixon v. Warner Comme'ns, Inc., 435 U.S. 589, 602 (1978). As with the
redactions to her renewed motion for bail, the proposed redactions here are narrowly
tailored to serve substantial interests, including, most importantly, third parties
personal privacy interests. See Under Seal v. Under Seal, 273 F. Supp. 3d 460, 467
|(S.D.N.Y. 2017). See also Dkt. No. 95. The Defendant is hereby ORDERED to docket
the redacted documents and corresponding exhibits by no later than December 23,
2020. SO ORDERED. (Signed by Judge Alison J. Nathan on 12/23/2020) (Inl)
(Entered: 12/23/2020)</td></tr><tr><td>12/23/2020</td><td>102</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated December 18, 2020 re: Cover Letter for Reply Memorandum for
Renewed Bail Application (Everdell, Christian) (Entered: 12/23/2020)</td></tr><tr><td>12/23/2020</td><td>103</td><td>REPLY MEMORANDUM OF LAW in Support by Ghislaine Maxwell re: Renewed
Motion for Bail. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Everdell, Christian)
(Entered: 12/23/2020)</td></tr><tr><td>12/28/2020</td><td>104</td><td>ORDER as to Ghislaine Maxwell. On December 8, 2020, Defendant Ghislaine
Maxwell filed a renewed motion for releaseon bail. Dkt No. 97. In an Opinion and
Order concurrently filed under temporary seal, the Court DENIES the Defendant's</td></tr></table>

# Case 21-58, Document 21-2, 03/24/2021, 3065978, Page19 of 25

<table><tr><th></th><th></th><th>motion. In light of the fact that the Opinion includes potentially confidential
information that should not be filed on the public docket, the Court will permit the
parties 48 hours to propose any redactions to the Courts Opinion and Order and to
justify those redactions by reference tothe Second Circuits decision in Lugosch v.
Pyramid Co. of Onondaga, 435 F.3d 110(2d Cir. 2006). After determining which, if
any, portions of the Opinion and Order should be redacted, the Court will file the
Opinion and Order on the public docket. As a result, the Court concludes that the
Government has met its burden of persuasion that the Defendant poses a flight risk and
that pretrial detention continues to be warranted. On or before December 30, 2020, the
parties are ORDERED to submit a joint letter indicating whether they propose any
redactions and the justification for any such proposal. This resolves Dkt No. 97.
(Signed by Judge Alison J. Nathan on 12/28/20)(jw) (Entered: 12/28/2020)</th></tr><tr><td>12/30/2020</td><td>105</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated December 30, 2020
re: Joint Letter re December 28, 2020 Opinion and Order Document filed by USA.
(Comey, Maurene) (Entered: 12/30/2020)</td></tr><tr><td>12/30/2020</td><td>106</td><td>OPINION AND ORDER as to Ghislaine Maxwell. Defendant Ghislaine Maxwell has
been indicted by a grand jury on charges of conspiracy to entice minors to travel to
engage in illegal sex acts, in violation of 18 U.S.C. § 371; enticing a minor to travel to
engage in illegal sex acts, in violation of 18 U.S.C. §§ 2422 and 2; conspiracy to
transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371;
transporting minors to participate in illegal sex acts, in violation of 18 U.S.C. §§ 2423
and 2; and two charges of perjury, in violation of 18 U.S.C. § 1623. The Court held a
lengthy bail hearing on July 14, 2020. After extensive briefing and argument at the
hearing, the Court concluded that the Defendant was a clear risk of flight and that no
conditions or combination of conditions would ensure her appearance. Defendant
Ghislaine Maxwells renewed motion for release on bail, Dkt. No. 97, is DENIED.
(Signed by Judge Alison J. Nathan on 12/28/20)(jw) (Entered: 12/30/2020)</td></tr><tr><td>12/31/2020</td><td>107</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated December 31, 2020 re: Extension of Time Document filed by Ghislaine
Maxwell. (Everdell, Christian) (Entered: 12/31/2020)</td></tr><tr><td>01/05/2021</td><td>108</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell (1) on 107 LETTER MOTION
addressed to Judge Alison J. Nathan from Christian R. Everdell dated December 31,
2020 re: Extension of Time. ENDORSEMENT: SO ORDERED. (Signed by Judge
Alison J. Nathan on 1/5/2021) (ap) (Entered: 01/05/2021)</td></tr><tr><td>01/05/2021</td><td></td><td>Set/Reset Deadlines as to Ghislaine Maxwell: Motions due by 1/25/2021. Responses
| due by 2/26/2021. Replies due by 3/5/2021. (ap) (Entered: 01/05/2021)</td></tr><tr><td>01/08/2021</td><td>109</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated January 8, 2021 re: Extension of Time to File Notice of Appeal. Document filed
by Ghislaine Maxwell. (Everdell, Christian) (Entered: 01/08/2021)</td></tr><tr><td>01/11/2021</td><td>110</td><td>SEALED DOCUMENT placed in vault. (jus) (Entered: 01/11/2021)</td></tr><tr><td>01/11/2021</td><td>111</td><td>SEALED DOCUMENT placed in vault. (jus) (Entered: 01/11/2021)</td></tr><tr><td>01/11/2021</td><td>112</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell (1) denying 109 LETTER
MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell dated
January 8, 2021 re: Extension of Time to File Notice of Appeal. ENDORSEMENT:
The request is denied. Good cause for an extension of time to file a notice of appeal
has not been provided. SO ORDERED. (Signed by Judge Alison J. Nathan on
1/11/2021) (Inl) (Entered: 01/11/2021)</td></tr><tr><td>01/11/2021</td><td>113</td><td>NOTICE OF APPEAL by Ghislaine Maxwell from 104 Order. (nd) (Entered:
01/12/2021)</td></tr><tr><td>01/11/2021</td><td></td><td>Appeal Remark as to re: 113 Notice of Appeal by Ghislaine Maxwell. $505.00 Appeal
filing fee due. (nd) (Entered: 01/12/2021)</td></tr><tr><td>01/12/2021</td><td></td><td>Transmission of Notice of Appeal and Certified Copy of Docket Sheet as to Ghislaine
| Maxwell to US Court of Appeals re: 113 Notice of Appeal. (nd) (Entered: 01/12/2021)</td></tr></table>

# Case 21-58, Document 21-2, 03/24/2021, 3065978, Page20 of 25

<table><tr><th>01/12/2021</th><th></th><th>Appeal Record Sent to USCA (Electronic File). Certified Indexed record on Appeal
Electronic Files as to Ghislaine Maxwell re: 113 Notice of Appeal were transmitted to
the U.S. Court of Appeals. (nd) (Entered: 01/12/2021)</th></tr><tr><td>01/13/2021</td><td>114</td><td>INTERNET CITATION NOTE as to Ghislaine Maxwell: Material from decision with
Internet citation re: 106 Memorandum &amp; Opinion. (sjo) (Entered: 01/13/2021)</td></tr><tr><td>01/14/2021</td><td>115</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated January 14, 2021 re: Laptop Access (Everdell, Christian) (Entered:
01/14/2021)</td></tr><tr><td>01/15/2021</td><td>116</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on 115 LETTER by Ghislaine
Maxwell addressed to Judge Alison J. Nathan from Christian R. Everdell dated
|January 14, 2021 re: Laptop Access. ENDORSEMENT: The unobjected-to request is
GRANTED. The Bureau of Prisons is ORDERED to give the Defendant access to the
laptop computer on weekends and holidays during the hours that she is permitted to
review discovery. SO ORDERED. (Signed by Judge Alison J. Nathan on 1/15/2021)
(Inl) (Entered: 01/15/2021)</td></tr><tr><td>01/15/2021</td><td></td><td>USCA Case Number 21-0058 from the U.S. Court of Appeals, 2nd Circ. as to
Ghislaine Maxwell, assigned to 113 Notice of Appeal filed by Ghislaine Maxwell. (nd)
(Entered: 01/15/2021)</td></tr><tr><td>01/15/2021</td><td></td><td>USCA Appeal Fees received $ 505.00, receipt number 465401271727 as to Ghislaine
Maxwell on 01/15/2021 re: 113 Notice of Appeal filed by Ghislaine Maxwell. (nd)
(Entered: 01/15/2021)</td></tr><tr><td>01/25/2021</td><td>117</td><td>ORDER as to Ghislaine Maxwell: On January 25, 2021, the Court received by email
the attached letter from the Bureau of Prisons ("BOP"). In the letter, the BOP requests
that the Court vacate its January 15, 2021 Order, Dkt. No. 116, which directed the
BOP to give the Defendant access to her Government provided laptop computer on
weekends and holidays during the hours that she is permitted to review discovery. The
Defendant and the Government may respond to the BOP's letter within one week of
this Order. (Signed by Judge Alison J. Nathan on 1/25/2021) (ap) (Entered:
01/25/2021)</td></tr><tr><td>01/25/2021</td><td>118</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Mark S.
Cohen dated January 25, 2021 re: Pretrial Motions (Cohen, Mark) (Entered:
01/25/2021)</td></tr><tr><td>01/25/2021</td><td>119</td><td>MOTION for Separate Trial on Counts Ghislaine Maxwell (1) Count 5s-6s,5-6.
Document filed by Ghislaine Maxwell. (Pagliuca, Jeffrey) (Entered: 01/25/2021)</td></tr><tr><td>01/25/2021</td><td>120</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 119 MOTION for Separate
Trial on Counts Ghislaine Maxwell (1) Count 5s-6s,5-6 .. (Pagliuca, Jeffrey)
|(Entered: 01/25/2021)</td></tr><tr><td>01/25/2021</td><td>121</td><td>MOTION to Dismiss Either Count One Or Count Three of the Superseding Indictment
as Multiplicitous. Document filed by Ghislaine Maxwell. (Pagliuca, Jeffrey) (Entered:
01/25/2021)</td></tr><tr><td>01/25/2021</td><td>122</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 121 MOTION to Dismiss
Either Count One Or Count Three of the Superseding Indictment as Multiplicitous..
(Pagliuca, Jeffrey) (Entered: 01/25/2021)</td></tr><tr><td>01/25/2021</td><td>123</td><td>MOTION to Dismiss Counts One through Four of the Superseding Indictment for
Lack of Specificity. Document filed by Ghislaine Maxwell. (Pagliuca, Jeffrey)
(Entered: 01/25/2021)</td></tr><tr><td>01/25/2021</td><td>124</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 123 MOTION to Dismiss
Counts One through Four of the Superseding Indictment for Lack of Specificity..
(Pagliuca, Jeffrey) (Entered: 01/25/2021)</td></tr><tr><td>01/25/2021</td><td>125</td><td>MOTION to Dismiss the Superseding Indictment as it was Obtained in Violation of
the Sixth Amendment. Document filed by Ghislaine Maxwell. (Cohen, Mark) (Entered:
01/25/2021)</td></tr><tr><td>01/25/2021</td><td>126</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 125 MOTION to Dismiss the
Superseding Indictment as it was Obtained in Violation of the Sixth Amendment..</td></tr></table>

# Case 21-58, Document 21-2, 03/24/2021, 3065978, Page21 of 25

<table><tr><th></th><th></th><th>(Cohen, Mark) (Entered: 01/25/2021)</th></tr><tr><td>01/26/2021</td><td>127</td><td>ORDER as to Ghislaine Maxwell: On January 25, 2021, the Defendant filed twelve
pre-trial motions. Because there is a request to redact sensitive or confidential
information, several of the motions have been filed under temporary seal. The
Government may respond to the Defendant's proposed redactions within two days of
this Order. (Signed by Judge Alison J. Nathan on 1/26/2021) (ap) (Entered:
01/26/2021)</td></tr><tr><td>01/28/2021</td><td>128</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated
January 28, 2021 re: Defendant's Proposed Redactions to Pre-Trial Motions
|Document filed by USA. (Pomerantz, Lara) (Entered: 01/28/2021)</td></tr><tr><td>02/01/2021</td><td>129</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAs Maurene Comey, Alison Moe, and Lara Pomerantz dated February 1, 2021 re:
MDC Laptop Access Document filed by USA. (Comey, Maurene) (Entered:
02/01/2021)</td></tr><tr><td>02/01/2021</td><td>130</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C.
Sternheim dated 02/02/2021 re: Opposition to MDC letter (Sternheim, Bobbi)
(Entered: 02/01/2021)</td></tr><tr><td>02/02/2021</td><td>131</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on Letter addressed to Judge
Alison J. Nathan from Sophia Papapetru (Staff Attorney, MDC Brooklyn, Federal
Bureau of Prisons) dated January 25, 2021. ENDORSEMENT: Having considered the
request submitted by the Bureau of Prisons ("BOP") that the Court vacate its January
15, 2021 Order, Dkt. No. 117, as well as the Government's and the Defendant's
responses, Dkt. Nos. 129, 130, the Court hereby DENIES the BOP's request to vacate
the Order. SO ORDERED. (Signed by Judge Alison J. Nathan on 2/2/2021)(bw)
(Entered: 02/02/2021)</td></tr><tr><td>02/04/2021</td><td>132</td><td>ORDER as to Ghislaine Maxwell: The Defendant is hereby ORDERED to docket the
redacted documents and corresponding exhibits by no later than February 5, 2021.
With respect to Motion 3, the Defendant is ORDERED to docket the version that
includes the Government's proposed redactions in addition to her own. SO
ORDERED. (Signed by Judge Alison J. Nathan on 2/4/2021)(See ORDER as set forth)
(Inl) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>133</td><td>MOTION to Suppress Under the Due Process Clause All Evidence Obtained from the
Governments Subpoena to REDACTED and to Dismiss Counts Five and Six.
Document filed by Ghislaine Maxwell. (Pagliuca, Jeffrey) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>134</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 133 MOTION to Suppress
Under the Due Process Clause All Evidence Obtained from the Governments
Subpoena to REDACTED and to Dismiss Counts Five and Six.. (Attachments: # 1
Exhibit A, #2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, #1
Exhibit G, #8 Exhibit H, #2 Exhibit I)(Pagliuca, Jeffrey) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>135</td><td>MOTION to Dismiss Counts Five and Six of the Superseding Indictment Because the
Alleged Misstatements are Not Perjurious as a Matter of Law. Document filed by
| Ghislaine Maxwell. (Pagliuca, Jeffrey) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>136</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 135 MOTION to Dismiss
Counts Five and Six of the Superseding Indictment Because the Alleged Misstatements
are Not Perjurious as a Matter of Law.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, #
3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H,
#2 Exhibit I, # 10 Exhibit J, # 11 Exhibit K)(Pagliuca, Jeffrey) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>137</td><td>MOTION to Dismiss Counts One Through Six of the Superseding Indictment for
Pre-Indictment Delay. Document filed by Ghislaine Maxwell. (Pagliuca, Jeffrey)
(Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>138</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 137 MOTION to Dismiss
Counts One Through Six of the Superseding Indictment for Pre-Indictment Delay..
(Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Pagliuca,
Jeffrey) (Entered: 02/04/2021)</td></tr></table>

# Case 21-58, Document 21-2, 03/24/2021, 3065978, Page22 of 25

<table><tr><th>02/04/2021</th><th>139</th><th>MOTION to Suppress Under the Fourth Amendment, Martindell, and the Fifth
Amendment All Evidence Obtained from the Governments Subpoena to REDACTED
and to Dismiss Counts Five And Six. Document filed by Ghislaine Maxwell. (Pagliuca,
Jeffrey) (Entered: 02/04/2021)</th></tr><tr><td>02/04/2021</td><td>140</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 139 MOTION to Suppress
Under the Fourth Amendment, Martindell, and the Fifth Amendment All Evidence
Obtained from the Governments Subpoena to REDACTED and to Dismiss Counts Five
And Six.. (Pagliuca, Jeffrey) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>141</td><td>MOTION to Dismiss the Superseding Indictment for Breach of Non-Prosecution
Agreement. Document filed by Ghislaine Maxwell. (Cohen, Mark) (Entered:
02/04/2021)</td></tr><tr><td>02/04/2021</td><td>142</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 141 MOTION to Dismiss the
Superseding Indictment for Breach of Non-Prosecution Agreement.. (Attachments: #
1 Exhibit A, #2 Exhibit B, # 3 Exhibit C (Sealed), # 4 Exhibit D (Sealed), # 5 Exhibit
E (Sealed), #6 Exhibit F (Sealed), # 7 Exhibit G (Sealed), #8 Exhibit H
(Sealed))(Cohen, Mark) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>143</td><td>MOTION to Dismiss Counts One Through Four of the Superseding Indictment as
Time-Barred. Document filed by Ghislaine Maxwell. (Cohen, Mark) (Entered:
02/04/2021)</td></tr><tr><td>02/04/2021</td><td>144</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 143 MOTION to Dismiss
Counts One Through Four of the Superseding Indictment as Time-Barred.. (Cohen,
Mark) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>145</td><td>MOTION to Strike Surplusage from Superseding Indictment. Document filed by
Ghislaine Maxwell. (Cohen, Mark) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>146</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 145 MOTION to Strike
Surplusage from Superseding Indictment.. (Cohen, Mark) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>147</td><td>MOTION for Bill of Particulars and Pretrial Disclosures. Document filed by
Ghislaine Maxwell. (Cohen, Mark) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>148</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 147 MOTION for Bill of
Particulars and Pretrial Disclosures.. (Attachments: # 1 Exhibit A, # 2 Exhibit B
(Sealed), #3 Exhibit C (Sealed), # 4 Exhibit D (Sealed), # 5 Exhibit E)(Cohen, Mark)
(Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>149</td><td>AFFIDAVIT of Bobbi C. Sternheim in Support as to Ghislaine Maxwell re 147
MOTION for Bill of Particulars and Pretrial Disclosures.. (Cohen, Mark) (Entered:
02/04/2021)</td></tr><tr><td>02/05/2021</td><td>150</td><td>SEALED DOCUMENT placed in vault. (jri) (Entered: 02/05/2021)</td></tr><tr><td>02/05/2021</td><td>151</td><td>SEALED DOCUMENT placed in vault. (jri) (Entered: 02/05/2021)</td></tr><tr><td>02/05/2021</td><td>152</td><td>SEALED DOCUMENT placed in vault. (jri) (Entered: 02/05/2021)</td></tr><tr><td>02/05/2021</td><td>153</td><td>SEALED DOCUMENT placed in vault. (jri) (Entered: 02/05/2021)</td></tr><tr><td>02/05/2021</td><td>154</td><td>SEALED DOCUMENT placed in vault. (jri) (Entered: 02/05/2021)</td></tr><tr><td>02/05/2021</td><td>155</td><td>SEALED DOCUMENT placed in vault. (jri) (Entered: 02/05/2021)</td></tr><tr><td>02/05/2021</td><td>156</td><td>SEALED DOCUMENT placed in vault. (jri) (Entered: 02/05/2021)</td></tr><tr><td>02/05/2021</td><td>157</td><td>SEALED DOCUMENT placed in vault. (jri) (Entered: 02/05/2021)</td></tr><tr><td>02/05/2021</td><td>158</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated February 5, 2021 re:
MDC Conditions Update Document filed by USA. (Comey, Maurene) (Entered:
02/05/2021)</td></tr><tr><td>02/16/2021</td><td>159</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C.
Sternheim dated 02/16/2021 re: Conditions of Pretrial Confinement (Sternheim,
Bobbi) (Entered: 02/16/2021)</td></tr></table>

# Case 21-58, Document 21-2, 03/24/2021, 3065978, Page23 of 25

<table><tr><th>02/23/2021</th><th>160</th><th>THIRD MOTION for Bond. Document filed by Ghislaine Maxwell. (Sternheim,
Bobbi) (Entered: 02/23/2021)</th></tr><tr><td>02/24/2021</td><td>161</td><td>ORDER as to Ghislaine Maxwell: On February 23, 2021, Defendant Ghislaine
Maxwell filed a third motion for release on bail. Dkt. No. 160. The Government's
response is due March 9, 2021, and the Defendants reply is due March 16, 2021. SO
ORDERED. (Responses due by 3/9/2021. Replies due by 3/16/2021.) (Signed by
Judge Alison J. Nathan on 2/24/2021) (Inl) (Entered: 02/24/2021)</td></tr><tr><td>02/26/2021</td><td>162</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated
February 26, 2021 re: Cover Letter for Government Opposition to Defense Pretrial
Motions Document filed by USA. (Comey, Maurene) (Entered: 02/26/2021)</td></tr><tr><td>03/01/2021</td><td>163</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated March 1, 2021 re: Extension of Time to File Reply to Government Opposition to
Defense Pretrial Motions. Document filed by Ghislaine Maxwell. (Everdell, Christian)
(Entered: 03/01/2021)</td></tr><tr><td>03/01/2021</td><td>164</td><td>MEMO ENDORSEMENT 163 LETTER MOTION To request a 10-day extension of
time until Monday, March 15, 2021 to file our reply re: 163 LETTER MOTION
addressed to Judge Alison J. Nathan from Christian R. Everdell dated March 1, 2021
re: Extension of Time to File Briefing Schedule...ENDORSEMENT... The Defendant's
request is GRANTED. Her reply to the Government's Omnibus Memorandum in
Opposition to the Defendants Pretrial Motions is now due on March 15, 2021. SO
ORDERED. (Signed by Judge Alison J. Nathan on 3/1/21) (jw) (Entered: 03/01/2021)</td></tr><tr><td>03/01/2021</td><td></td><td>Set/Reset Deadlines/Hearings as to Ghislaine Maxwell: Defendant Replies due by
3/15/2021 (jw) (Entered: 03/01/2021)</td></tr><tr><td>03/09/2021</td><td>165</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAs Maurene Comey, Alison Moe, and Lara Pomerantz dated March 9, 2021 re:
Opposition to Third Bail Motion Document filed by USA. (Attachments: # 1 Exhibit
A)(Pomerantz, Lara) (Entered: 03/09/2021)</td></tr><tr><td>03/15/2021</td><td>166</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated March 15, 2021 re: Pretrial Motion Replies (Everdell, Christian)
(Entered: 03/15/2021)</td></tr><tr><td>03/16/2021</td><td>167</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C.
Sternheim dated 03/16/2021 re: Letter regarding Reply to Bail Motion (Sternheim,
Bobbi) (Entered: 03/16/2021)</td></tr><tr><td>03/18/2021</td><td>168</td><td>ORDER as to Ghislaine Maxwell. On February 26, 2021, the Government filed its
omnibus memorandum of law opposing Defendants' twelve pretrial motions. It filed
the brief, along with the corresponding exhibits, under temporary seal pending the
Court's resolution of its request to redact sensitive or confidential information. See
Dkt. No. 162. On March 9, 2021, the Defendant objected to certain of the redactions
that the Government had proposed, and she proposed additional redactions. Having
considered the parties' respective positions, the Court will grant the Government's
requests for redactions and sealing, as well as the Defendant's additional redaction
requests, with the exceptions discussed below. Finally, the Court denies the
Governments request to file Exhibit 11 entirely under seal. While portions of that
transcript have been redacted, other portions are part of the public record. See Giuffre
v. Maxwell, Case No. 15-cv-7433, Dkt. No. 1212-1. In light of this, the Court sees
no basis to file the transcript entirely under seal rather than by redacting the relevant
portions. In light of the above, the Government is hereby ORDERED to either docket
on ECF their brief and the corresponding exhibits, consistent with this Order, or to file
a letter with the Court justifying more tailored redaction and sealing requests regarding
pages 1128 and 187188 and Exhibits 8 and 9 by no later than March 22, 2021. The
parties are further ORDERED to meet, confer, and jointly propose redactions to the
Defendant's cover letter objecting to the Government's proposed redactions by March
22, 2021. Finally, the parties are ORDERED to meet, confer, and propose redactions
to Exhibit 11 of the Government's submission by March 22, 2021 (Signed by Judge
Alison J. Nathan on 3/18/21)(jw) (Entered: 03/18/2021)</td></tr></table>

# Case 21-58, Document 21-2, 03/24/2021, 3065978, Page24 of 25

<table><tr><th>03/22/2021</th><th>169</th><th>ORDER as to Ghislaine Maxwell: Defendant Ghislaine Maxwell's third motion for
release on bail, Dkt. No. 160, is DENIED. The parties are ORDERED to meet and
confer and propose and justify any redactions to the Defendant's reply brief by March
24, 2021. If they conclude that redactions are unnecessary, the Defendant is
ORDERED to docket the unredacted version of the brief by March 24, 2021. (Signed
by Judge Alison J. Nathan on 3/22/2021) (See ORDER set forth) (ap) Modified on
| 3/23/2021 (ap). (Entered: 03/22/2021)</th></tr><tr><td>03/22/2021</td><td>170</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated
March 22, 2021 re: Redactions to Government Opposition to Defense Pretrial Motions
Document filed by USA. (Pomerantz, Lara) (Entered: 03/22/2021)</td></tr><tr><td>03/23/2021</td><td>171</td><td>REPLY MEMORANDUM OF LAW in Support as to Ghislaine Maxwell re: 160
THIRD MOTION for Bond. . (Sternheim, Bobbi) (Entered: 03/23/2021)</td></tr><tr><td>03/24/2021</td><td>172</td><td>ORDER as to Ghislaine Maxwell. On March 5, 2021, Defendant Ghislaine Maxwell
submitted to the Court an application for an order authorizing a subpoena pursuant to
Rule 17(c)(3) of the Federal Rules of Criminal Procedure. The proposed subpoena was
directed at a law firm that represents alleged victims of the Defendant. As is standard
for Rule 17(c) subpoenas, the application was made ex parte and under seal on the
ground that it reveals defense strategy.... [*** See this Order ***]... Rule 17(c)(3)
provides that "[a]fter [an indictment] is filed, a subpoena requiring the production of
personal or confidential information about a victim may be served on a third party only
by court order," but "before entering the order and unless there are exceptional
circumstances, the court must require giving notice to the victim so that the victim can
move to quash or modify the subpoena or otherwise object." Fed. R. Crim. P. 17(c)(3).
Consistent with the Rule, on March 12, 2021, in a sealed ex parte Order, the Court
required defense counsel to provide notice to alleged victims whose personal or
confidential information may be disclosed by the proposed subpoena. The Court also
gave the alleged victims an opportunity to object to or request modifications of the
subpoena as required by Rule 17(c)(3). On March 19, 2021, the Court received a letter
from the law firm indicating that it can provide notice to alleged victims whose
personal or confidential information may be elicited by the subpoena. The law firm
shall provide notice to any such alleged victims it represents. In that letter, the law firm
also interposed substantial objections on behalf of the law firm and the alleged victims
it represents. Those objections are functionally the equivalent of a motion to quash,
even though the subpoena has not yet issued. So that the Court can receive adversarial
briefing on the proposed subpoena comparable to a motion to quash, the law firm shall
enter an appearance and file its objections on the public docket. See United States v.
Ray, No. 20-CR-110 (LJL), 2020 WL 6939677, at *10 (S.D.N.Y. Nov. 25, 2020)
("[I]f the Court determines that the subpoena calls for personal or confidential
information about a victim, it requires the requesting party have given notice to the
victim before it permits the service of the subpoena. If the victim objects, the Court
will then determine whether to modify or quash the subpoena, including on grounds
that Nixon was not satisfied."). In advance of noticing an appearance and filing, the
law firm shall meet and confer with defense counsel to see if any issues can be
narrowed before formal briefing. Moreover, prior to filing, the law firm shall confer
with defense counsel as to any proposed, necessary, and tailored redactions to the
objections. The law firm's objections with any proposed redactions shall be filed on or
before March 26, 2021. Any redactions must be justified consistent with Lugosch v.
Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Within one week of the filing
of objections, defense counsel may respond to the subpoena objections. The law firm
may reply within three days of the Defendant's response. (See Citation 1 on this Order).
Counsel shall confer regarding any proposed redactions for all briefing. SO
ORDERED. (Signed by Judge Alison J. Nathan on 3/24/2021)(bw) (Entered:
03/24/2021)</td></tr><tr><td>03/24/2021</td><td>173</td><td>NOTICE OF APPEAL by Ghislaine Maxwell from 169 Order, Terminate Motions.
(tp) (Entered: 03/24/2021)</td></tr><tr><td>03/24/2021</td><td></td><td>Appeal Remark as to Ghislaine Maxwell re: 173 Notice of Appeal. $505.00 Appeal
Fee Due. (tp) (Entered: 03/24/2021)</td></tr><tr><td>03/24/2021</td><td></td><td>Transmission of Notice of Appeal and Certified Copy of Docket Sheet as to Ghislaine
Maxwell to US Court of Appeals re: 173 Notice of Appeal. (tp) (Entered: 03/24/2021)</td></tr></table>

# Case 21-58, Document 21-2, 03/24/2021, 3065978, Page25 of 25

<table><tr><th>03/24/2021</th><th></th><th>Appeal Record Sent to USCA (Electronic File). Certified Indexed record on Appeal
Electronic Files as to Ghislaine Maxwell re: 173 Notice of Appeal were transmitted to
the U.S. Court of Appeals. (tp) (Entered: 03/24/2021)</th></tr><tr><td>03/24/2021</td><td>174</td><td>SEALED DOCUMENT placed in vault. (dn) (Entered: 03/24/2021)</td></tr><tr><td>03/24/2021</td><td>175</td><td>SEALED DOCUMENT placed in vault. (dn) (Entered: 03/24/2021)</td></tr><tr><td>03/24/2021</td><td>176</td><td>SEALED DOCUMENT placed in vault. (dn) (Entered: 03/24/2021)</td></tr></table>

Case

1.202c-00330-AunenDocument/2015/1

Criminal Notice of Appeal Form A

DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 3/24/2021

# NOTICE OF APPEAL

United States District Court

Southern

District of New York

Caption:
United States of America v.
Ghislaine Maxwell
Docket No.: 20-CR-00330-AJN
Alison J. Nathan
(District Court Judge)
Notice is hereby given that Ghislaine Maxwell appeals to the United States Court of
Appeals for the Second Circuit from the judgment [ ] other | [x] Order on Third Motion for Release on Bail (Doc. 169)
entered in this action on March 22, 2021
(date)
(specify)
This appeal concerns: Conviction only [ ] | Sentence only [ ] | Conviction & Sentence [ ] | Other [x]
Defendant found guilty by plea [ ] trial [ ] N/A |
Offense occurred after November 1, 1987? Yes | No [ ]
N/A |
Date of sentence: N/A |
Bail/Jail Disposition: Committed [x] | Not committed | N/A |
Appellant is represented by counsel? Yes [x] No [ ] If yes, provide the following information:
Defendant's Counsel: David Oscar Markus
Counsel's Address: Markus/Moss PLLC
40 NW Third Street, Ph 1, Miami, Florida 33128
Counsel's Phone: (305)379-6667
Assistant U.S. Attorney: Maureen Comey, Alison Moe & Lara Pomerantz
AUSA's Address: The Silvio J. Mollo Building
One Saint Andrew's Plaza, New York, New York 10007
AUSA's Phone: (212)637-2324
<signature>

Signature

# NOTICE OF APPEAL (cont.)

Case 21-58, Document 23, 03/29/2021, 3065988, Page2 of 24

APPEAL,ECF,INTAPP

# U.S. District Court Southern District of New York (Foley Square) CRIMINAL DOCKET FOR CASE #: 1:20-cr-00330-AJN All Defendants

Case title: USA v. Maxwell

Date Filed: 06/29/2020

Assigned to: Judge Alison J.
Nathan

Appeals court case number:
21-0058 U.S. Court of Appeals,
2nd Circ.

# U.S. District Court Southern District of New York (Foley Square) CRIMINAL DOCKET FOR CASE #: 1:20-cr-00330-AJN All Defendants (cont.)

## Defendant (1)

Ghislaine Maxwell
also known as
Sealed Defendant 1

represented by Christian R. Everdell
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
212-707-7268
Fax: 212-957-4514
Email: ceverdell@cohengresser.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Jeffrey S. Pagliuca
Haddon Morgan and Foreman
150 East 10th Avenue
Denver, CO 80203
(303)-831-7364
Fax: (303)-832-2628
Email: ipagliuca@hmflaw.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Laura A. Menninger
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
(303)-831-7364
Fax: (303)-832-2628
Email: lmenninger@hmflaw.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Mark Stewart Cohen
Cohen & Gresser, LLP (NYC)
800 Third Avenue
New York, NY 10022
(212) 957-7600
Fax: (212)957-4514
Email: mcohen@cohengresser.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Bobbi C Sternheim
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
(212) 243-1100
Fax: (888) 587-4737
Email: bc@sternheimlaw.com

# Case 21-58, Document 23, 03/29/2021, 3065988, Page3 of 24

ATTORNEY TO BE NOTICED

Pending Counts

Disposition

18:371.F CONSPIRACY TO
ENTICE MINORS TO TRAVEL
TO ENGAGE IN ILLEGAL SEX
ACTS
(1)

18:371.F CONSPIRACY TO
ENTICE MINORS TO TRAVEL
TO ENGAGE IN ILLEGAL SEX
ACTS
(1s)

18:2422.F COERCION OR
ENTICEMENT OFA MINOT TO
TRAVEL TO ENGAGE IN
ILLEGAL SEX ACTS
(2)

18:2422.F COERCION OR
ENTICEMENT OF MINOR TO
ENGAGE IN ILLEGAL SEX
ACTS
(2s)

18:371.F CONSPIRACY TO
TRANSPORT MINORS WITH
INTENT TO ENGAGE IN
CRIMINAL SEXUAL ACTIVITY
(3)

18:371.F 18:371.F CONSPIRACY
TO TRANSPORT MINORS WITH
INTENT TO ENGAGE IN
CRIMINAL SEXUAL ACTIVITY
(3s)

18:2423.F COERCION OR
ENTICEMENT OF MINOR
FEMALE (TRANSPORTATION
OF A MINOR WITH INTENT TO
ENGAGE IN CRIMINAL
SEXUAL ACTIVITY)
(4)

18:2423.F TRANSPORTATION
OF A MINOR WITH INTENT TO
ENGAGE IN CRIMINAL
SEXUAL ACTIVITY
(4s)

18:1623.F FALSE
DECLARATIONS BEFORE
GRAND JURY/COURT
(PERJURY)
(5-6)

18:1623.F FALSE
DECLARATIONS BEFORE
GRAND JURY/COURT
(5s-6s)

## Highest Offense Level (Opening)

Felony

# Case 21-58, Document 23, 03/29/2021, 3065988, Page4 of 24

Terminated Counts

None

- Highest Offense Level
(Terminated)

None

Complaints
None

Plaintiff

USA

Disposition

Disposition

represented by Alex Rossmiller
U.S. Attorney's Office, Southern District of
New York
1 St. Andrew's Plaza
New York, NY 10007
(212) 637-2415
Email: alexander.rossmiller@usdoj.gov
LEAD ATTORNEY
PRO HAC VICE
ATTORNEY TO BE NOTICED
Designation: Assistant US Attorney

Alison Gainfort Moe
United States Attorney's Office, SDNY
One Saint Andrew's Plaza
New York, NY 10007
(212) 637-2225
Email: alison.moe@usdoj.gov
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Designation: Assistant US Attorney

Maurene Ryan Comey
United States Attorney's Office, SDNY
One Saint Andrew's Plaza
New York, NY 10007
(212) 637-2324
Email: maurene.comey@usdoj.gov
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Designation: Assistant US Attorney

Andrew Rohrbach
DOJ-USAO
1 St. Andrew's Plaza
New York, NY 10007
212-637-2345
Email: Andrew.Rohrbach@usdoj.gov
ATTORNEY TO BE NOTICED

Lara Elizabeth Pomerantz
United States Attorney's Office
One St. Andrew's Plaza
New York, NY 10007
212-637-2343
Fax: 212-637-2527
Email: Lara.Pomerantz@usdoj.gov
ATTORNEY TO BE NOTICED

# Case 21-58, Document 23, 03/29/2021, 3065988, Page5 of 24

<table><tr><th>Date Filed</th><th>#</th><th>Docket Text</th></tr><tr><td>06/29/2020</td><td>1</td><td>SEALED INDICTMENT as to Sealed Defendant 1 (1) count(s) 1, 2, 3, 4, 5-6. (jm)
(Main Document 1 replaced on 7/2/2020) (jm). (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td>2</td><td>Order to Unseal Indictment as to Sealed Defendant 1. (Signed by Magistrate Judge
Katharine H. Parker on 7/2/20)(jm) (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td></td><td>| INDICTMENT UNSEALED as to Ghislaine Maxwell. (jm) (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td></td><td>Case Designated ECF as to Ghislaine Maxwell. (jm) (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td></td><td>Case as to Ghislaine Maxwell ASSIGNED to Judge Alison J. Nathan. (jm) (Entered:
07/02/2020)</td></tr><tr><td>07/02/2020</td><td></td><td>Attorney update in case as to Ghislaine Maxwell. Attorney Alex Rossmiller, Maurene
Ryan Comey,Alison Gainfort Moe for USA added. (jm) (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td>4</td><td>MOTION to detain defendant. Document filed by USA as to Ghislaine Maxwell.
(Moe, Alison) (Entered: 07/02/2020)</td></tr><tr><td>07/02/2020</td><td></td><td>Arrest of Ghislaine Maxwell in the United States District Court - District of New
Hampshire. (jm) (Entered: 07/06/2020)</td></tr><tr><td>07/05/2020</td><td>5</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Alex Rossmiller dated July 5, 2020 re:
Request to Schedule Initial Appearance Document filed by USA. (Comey, Maurene)
(Entered: 07/05/2020)</td></tr><tr><td>07/06/2020</td><td>6</td><td>Rule 5(c)(3) Documents Received as to Ghislaine Maxwell from the United States
District Court District of New Hampshire. (jm) (Entered: 07/06/2020)</td></tr><tr><td>07/06/2020</td><td>7</td><td>ORDER as to Ghislaine Maxwell. This matter has been assigned to me for all
purposes. In its July 5, 2020 letter, the Government on behalf of the parties requested
that the Court schedule an arraignment, initial appearance, and bail hearing in this
matter in the afternoon of Friday, July 10. See Dkt. No. 5. In light of the COVID
public health crisis, there are significant safety issues related to in-court proceedings.
If the Defendant is willing to waive her physical presence, this proceeding will be
conducted remotely. To that end, defense counsel should confer with the Defendant
regarding waiving her physical presence. If the Defendant wishes to waive her
physical presence for this proceeding, she and her counsel should sign the attached
form in advance of the proceeding if feasible. If this proceeding is to be conducted
remotely, there are protocols at the Metropolitan Detention Center that limit the times
at which the Defendant could be produced so that she could appear by video. In the
next week, the Defendant could be produced by video at either 9:00 a.m. on July 9,
2020 or sometime during the morning of July 14, 2020. Counsel are hereby ordered to
meet and confer regarding scheduling for this initial proceeding in light of these
constraints. If counsel does anticipate proceeding remotely, by 9:00 p.m. tonight,
counsel should file a joint letter proposing a date and time for the proceeding
consistent with this scheduling information, as well as a revised briefing schedule for
the Defendant's bail application.SO ORDERED. (Signed by Judge Alison J. Nathan on
7/6/2020)(jbo) (Entered: 07/06/2020)</td></tr><tr><td>07/06/2020</td><td>8</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Mark S.
Cohen dated July 6, 2020 re: Scheduling (Cohen, Mark) (Entered: 07/06/2020)</td></tr><tr><td>07/07/2020</td><td>2</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
Alex Rossmiller dated July 7, 2020 re: scheduling Document filed by USA.
(Rossmiller, Alex) (Entered: 07/07/2020)</td></tr><tr><td>07/07/2020</td><td>10</td><td>ORDER as to Ghislaine Maxwell. An arraignment, initial conference, and bail hearing
in this matter is hereby scheduled to occur as a remote video/teleconference using an
internet platform on July 14, 2020 at 1 p.m. In advance of the conference, Chambers
will email counsel with further information on how to access the video conference. To
optimize the quality of the video feed, only the Court, the Defendant, defense counsel,
and counsel for the Government will appear by video for the proceeding; all others
may access the audio of the public proceeding by telephone. Due to the limited</td></tr></table>

# Case 21-58, Document 23, 03/29/2021, 3065988, Page6 of 24

<table><tr><th></th><th></th><th>capacity of the internet platform system, only one attorney per party may participate
by video. Co-counsel, members of the press, and the public may access the audio feed
of the proceeding by calling a dial-in number, which the Court will provide in
advance of the proceeding by subsequent order. Given the high degree of public
interest in this case, a video feed of the remote proceeding will be available for
viewing in the Jury Assembly Room located at the Daniel Patrick Moynihan
Courthouse, 500 Pearl Street, New York, NY. Due to social distancing requirements,
seating will be extremely limited; when capacity is reached no additional persons will
be admitted. Per the S.D.N.Y. COVID-19 Courthouse Entry Program, anyone who
appears at any S.D.N.Y. courthouse must complete a questionnaire on the date of the
proceeding prior to arriving at the courthouse. All visitors must also have their
temperature taken when they arrive at the courthouse. Please see the instructions,
attached. Completing the questionnaire ahead of time will save time and effort upon
entry. Only persons who meet the entry requirements established by the questionnaire
and whose temperatures are below 100.4 degrees will be allowed to enter the
courthouse. Face coverings that cover the nose and mouth must be worn at all times.
| Anyone who fails to comply with the COVID-19 protocols that have been adopted by
the Court will be required to leave the courthouse. There are no exceptions. As
discussed in the Court's previous order, defense counsel shall, if possible, discuss the
Waiver of Right to be Present at Criminal Proceeding with the Defendant prior to the
proceeding. See Dkt. No. 7. If the Defendant consents, and is able to sign the form
(either personally or, in accordance with Standing Order 20-MC-174 of March 27,
2020, by defense counsel), defense counsel shall file the executed form at least 24
hours prior to the proceeding. In the event the Defendant consents, but counsel is
unable to obtain or affix the Defendant's signature on the form, the Court will conduct
an inquiry at the outset of the proceeding to determine whether it is appropriate for the
Court to add the Defendant's signature to the form. Pursuant to 18 U.S.C. § 3771(c)(1),
the Government must make their best efforts to see that crime victims are notified of,
and accorded, the rights provided to them in that section. This includes [t]he right to
reasonable, accurate, and timely notice of any public court proceeding... involving the
crime or of any release... of the accused and "[t]he right to be reasonably heard at any
public proceeding in the district court involving release." Id. § 3771(a)(2), (4). The
Court will inquire with the Government as to the extent of those efforts. So that
appropriate logistical arrangements can be made, the Government shall inform the
Court by email within 24 hours in advance of the proceeding if any alleged victim
wishes to be heard on the question of detention pending trial. Finally, the time between
the Defendant's arrest and July 6, 2020 is excluded under the Speedy Trial Act due to
the delay involved in transferring the Defendant from another district. See 18 U.S.C. §
3161(h)(1)(F). And the Court further excludes time under the Speedy Trial Act from
today through July 14, 2020. Due to the logistical issues involved in conducting a
remote proceeding, the Court finds "that the ends of justice served by [this exclusion]
outweigh the best interest of the public and the defendant in a speedy trial." 18 U.S.C.
§ 3161(h)(7)(A). The exclusion is also supported by the need for the parties to discuss
a potential protective order, which will facilitate the timely production of discovery in
a manner protective of the rights of third parties. See Dkt. No. 5. SO ORDERED.
(Signed by Judge Alison J. Nathan on 7/7/2020)(jbo) (Entered: 07/07/2020)</th></tr><tr><td>07/08/2020</td><td>11</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on 2 LETTER by USA as to
Ghislaine Maxwell addressed to Judge Alison J. Nathan from Alex Rossmiller dated
July 7, 2020 re: scheduling. ENDORSEMENT: The Court hereby sets the following
briefing schedule. The Defense response is due by 1:00 p.m. on July 10, 2020. The
Government reply is due by 1:00 p.m. on July 13, 2020. Additionally, defense counsel
is ordered to file notices of appearance on the docket by the end of the day today. SO
ORDERED. (Responses due by 7/10/2020. Replies due by 7/13/2020.) (Signed by
Judge Alison J. Nathan on 7/8/2020) (Inl) (Entered: 07/08/2020)</td></tr><tr><td>07/08/2020</td><td>12</td><td>NOTICE OF ATTORNEY APPEARANCE: Mark Stewart Cohen appearing for
| Ghislaine Maxwell. Appearance Type: Retained. (Cohen, Mark) (Entered: 07/08/2020)</td></tr><tr><td>07/08/2020</td><td>13</td><td>NOTICE OF ATTORNEY APPEARANCE: Christian R. Everdell appearing for
Ghislaine Maxwell. Appearance Type: Retained. (Everdell, Christian) (Entered:
07/08/2020)</td></tr><tr><td>07/08/2020</td><td>14</td><td>NOTICE OF ATTORNEY APPEARANCE: Laura A. Menninger appearing for
Ghislaine Maxwell. Appearance Type: Retained. (Menninger, Laura) (Entered:</td></tr></table>

# Case 21-58, Document 23, 03/29/2021, 3065988, Page7 of 24

<table><tr><th></th><th></th><th>07/08/2020)</th></tr><tr><td>07/08/2020</td><td>15</td><td>MOTION for Jeffrey S. Pagliuca to Appear Pro Hac Vice. Filing fee $ 200.00, receipt
number ANYSDC-20605229. Motion and supporting papers to be reviewed by
Clerk's Office staff. Document filed by Ghislaine Maxwell. (Attachments: # 1 Exhibit
Declaration of Jeffrey S. Pagliuca, # 2 Exhibit Certificate of Good Standing, #3 Text
of Proposed Order Proposed Order)(Pagliuca, Jeffrey) (Entered: 07/08/2020)</td></tr><tr><td>07/08/2020</td><td>17</td><td>(S1) SUPERSEDING INDICTMENT FILED as to Ghislaine Maxwell (1) count(s) 1s,
2s, 3s, 4s, 5s-6s. (jm) (Entered: 07/10/2020)</td></tr><tr><td>07/09/2020</td><td></td><td>|&gt;&gt;&gt;NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document
No. 15 MOTION for Jeffrey S. Pagliuca to Appear Pro Hac Vice. Filing fee $
200.00, receipt number ANYSDC-20605229. Motion and supporting papers to be
reviewed by Clerk's Office staff. The document has been reviewed and there are
no deficiencies. (aea) (Entered: 07/09/2020)</td></tr><tr><td>07/09/2020</td><td>16</td><td>ORDER as to Ghislaine Maxwell. As discussed in its previous order, the Court will
hold an arraignment, initial conference, and bail hearing in this matter remotely as a
video/teleconference on July 14, 2020 at 1 pm. Members of the press and the public in
the United States may access the live audio feed of the proceeding by calling
855-268-7844 and using access code 32091812# and PIN 9921299#. Those outside of
the United States may access the live audio feed by calling 214-416-0400 and using
the same access code and PIN. These phone lines can accommodate approximately
500 callers on a first come, first serve basis. The Court will provide counsel for both
sides an additional dial-in number to be used to ensure audio access to the proceeding
for non-speaking co-counsel, alleged victims, and any family members of the
Defendant. The United States Attorney's Office should email Chambers with
information regarding any alleged victims who are entitled, pursuant to 18 U.S.C.
$3771(a)(4), to be heard at the bail hearing and who wish to be heard. The Court will
then provide information as to the logistics for their dial-in access. As the Court
described in a previous order, members of the press and public may watch and listen to
the live video feed in the Jury Assembly Room, at the Daniel Patrick Moynihan
Courthouse, 500 Pearl Street. See Dkt. No. 10. However, in light of COVID-19,
seating will be limited to approximately 60 seats in order to enable appropriate social
distancing and ensure public safety. Counsel for the Defendant and the Government
may contact Chambers by email if there is a request to accommodate alleged victims
or family members of the Defendant. Members of the credentialed in-house press
corps may contact the District Executive's Office about seating. Otherwise, all seating
will be allocated on a first come, first serve basis and in accordance with the S.D.N.Y.
| COVID-19 Courthouse Entry Program and this Court's previous order of July 7, 2020.
|See Dkt. No. 10. If conditions change or the Court otherwise concludes that allowing
for in-person viewing of the video feed at the courthouse is not consistent with public
health, the Court may provide audio access by telephone only. Any photographing,
recording, or rebroadcasting of federal court proceedings is prohibited by law.
Violation of these prohibitions may result in fines or sanctions, including removal of
court issued media credentials, restricted entry to future hearings, denial of entry to
future hearings, or any other sanctions deemed necessary by the Court. SO
ORDERED. (Signed by Judge Alison J. Nathan on 7/9/2020)(jbo) (Entered:
07/09/2020)</td></tr><tr><td>07/10/2020</td><td>18</td><td>MEMORANDUM in Opposition by Ghislaine Maxwell re 4 MOTION to detain
defendant.. (Cohen, Mark) (Entered: 07/10/2020)</td></tr><tr><td>07/10/2020</td><td>19</td><td>NOTICE OF ATTORNEY APPEARANCE: Mark Stewart Cohen appearing for
| Ghislaine Maxwell. Appearance Type: Retained. (Cohen, Mark) (Entered: 07/10/2020)</td></tr><tr><td>07/10/2020</td><td>20</td><td>NOTICE OF ATTORNEY APPEARANCE: Christian R. Everdell appearing for
Ghislaine Maxwell. Appearance Type: Retained. (Everdell, Christian) (Entered:
07/10/2020)</td></tr><tr><td>07/10/2020</td><td>21</td><td>WAIVER of Personal Appearance at Arraignment and Entry of Plea of Not Guilty by
Ghislaine Maxwell. (Everdell, Christian) (Entered: 07/10/2020)</td></tr><tr><td>07/13/2020</td><td>22</td><td>REPLY MEMORANDUM OF LAW in Support by USA as to Ghislaine Maxwell re:
4 MOTION to detain defendant. . (Moe, Alison) (Entered: 07/13/2020)</td></tr></table>

# Case 21-58, Document 23, 03/29/2021, 3065988, Page8 of 24

<table><tr><th>07/13/2020</th><th></th><th>ORDER granting 15 Motion for Jeffrey Pagliuca to Appear Pro Hac Vice as to
Ghislaine Maxwell (1). (Signed by Judge Alison J. Nathan on 7/13/2020) (kwi)
(Entered: 07/13/2020)</th></tr><tr><td>07/14/2020</td><td>23</td><td>ORDER as to Ghislaine Maxwell. For the reasons stated on the record at today's
proceeding, the Governments motion to detain the Defendant pending trial is hereby
GRANTED (Signed by Judge Alison J. Nathan on 7/14/20)(jw) (Entered: 07/14/2020)</td></tr><tr><td>07/14/2020</td><td></td><td>Minute Entry for proceedings held before Judge Alison J. Nathan:Arraignment as to
Ghislaine Maxwell (1) Count 1s,2s,3s, 4s, 5s-6s held on 7/14/2020. Defendant
Ghislaine Maxwell present by video conference with attorney Mark Cohen present by
video conference, AUSA Alison Moe, Alex Rossmiller and Maurene Comey for the
government present by video conference, Pretrial Service Officer Lea Harmon present
by telephone and Court Reporter Kristine Caraannante. Defendant enters a plea of Not
Guilty to the S1 indictment. Trial set for July 12, 2021. See Order. Time is excluded
under the Speedy Trial Act from today until July 12, 2021. Bail is denied. Defendant is
| remanded. See Transcript. (jw) (Entered: 07/14/2020)</td></tr><tr><td>07/14/2020</td><td></td><td>Minute Entry for proceedings held before Judge Alison J. Nathan: Plea entered by
Ghislaine Maxwell (1) Count 1s,2s,3s, 4s, 5s-6s Not Guilty. (jw) (Entered: 07/14/2020)</td></tr><tr><td>07/14/2020</td><td>24</td><td>Waiver of Right to be Present at Criminal Proceeding as to Ghislaine Maxwell re:
Arraignment, Bail Hearing, Conference. (jw) (Entered: 07/14/2020)</td></tr><tr><td>07/15/2020</td><td>25</td><td>ORDER as to Ghislaine Maxwell. Initial non-electronic discovery, generally to
include search warrant applications and subpoena returns, is due by Friday, August 21,
2020. Completion of discovery, to include electronic materials, is due by Monday,
November 9, 2020. Motions are due by Monday, December 21, 2020. Motion
responses are due by Friday, January 22, 2021. Motion replies are due by Friday,
February 5, 2021. Trial is set for Monday, July 12, 2021 (Discovery due by
8/21/2020., Motions due by 12/21/2020) (Signed by Judge Alison J. Nathan on
7/15/20)(jw) (Entered: 07/15/2020)</td></tr><tr><td>07/21/2020</td><td>26</td><td>ORDER as to Ghislaine Maxwell: The Court has received a significant number of
letters and messages from non-parties that purport to be related to this case. These
submissions are either procedurally improper or irrelevant to the judicial function.
Therefore, they will not be considered or docketed. The Court will accord the same
treatment to any similar correspondence it receives in the future. SO ORDERED.
(Signed by Judge Alison J. Nathan on 7/21/2020) (Inl) (Entered: 07/21/2020)</td></tr><tr><td>07/21/2020</td><td>27</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Jeffrey S. Pagliuca
dated July 21, 2020 re: Local Criminal Rule 23.1. Document filed by Ghislaine
Maxwell. (Pagliuca, Jeffrey) (Entered: 07/21/2020)</td></tr><tr><td>07/23/2020</td><td>28</td><td>ORDER as to Ghislaine Maxwell: The Defense has moved for an order "prohibiting
the Government, its agents and counsel for witnesses from making extrajudicial
statements concerning this case." Dkt. No. 27 at 1. The Court firmly expects that
counsel for all involved parties will exercise great care to ensure compliance with this
| Court's local rules, including Local Criminal Rule 23.1, and the rules of professional
responsibility. In light of this clear expectation, the Court does not believe that further
action is needed at this time to protect the Defendant's right to a fair trial by an
impartial jury. Accordingly, it denies the Defendant's motion without prejudice. But
the Court warns counsel and agents for the parties and counsel for potential witnesses
that going forward it will not hesitate to take appropriate action in the face of
| violations of any relevant rules. The Court will ensure strict compliance with those
rules and will ensure that the Defendant's right to a fair trial will be safeguarded.
(Signed by Judge Alison J. Nathan on 7/23/2020) (ap) (Entered: 07/23/2020)</td></tr><tr><td>07/27/2020</td><td>29</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated July 27, 2020 re: Proposed Protective Order. Document filed by Ghislaine
Maxwell. (Attachments: # 1 Exhibit A (Proposed Protective Order))(Everdell,
Christian) (Entered: 07/27/2020)</td></tr><tr><td>07/27/2020</td><td>30</td><td>AFFIDAVIT of Christian R. Everdell by Ghislaine Maxwell. (Everdell, Christian)
(Entered: 07/27/2020)</td></tr><tr><td>07/27/2020</td><td>31</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
Alison Moe dated July 27, 2020 re: requesting until 5 p.m. tomorrow to respond to</td></tr></table>

# Case 21-58, Document 23, 03/29/2021, 3065988, Page9 of 24

<table><tr><th></th><th></th><th>defense counsel's letter, filed July 27, 2020 Document filed by USA. (Moe, Alison)
(Entered: 07/27/2020)</th></tr><tr><td>07/27/2020</td><td>32</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on 31 LETTER by USA as to
Ghislaine Maxwell addressed to Judge Alison J. Nathan from Alison Moe dated July
27, 2020 re: requesting until 5 p.m. tomorrow to respond to defense counsel's letter,
filed July 27, 2020. ENDORSEMENT: The Government's response to the Defense's
letter is due by 5 p.m. on July 28, 2020. The Defense may file a reply by 5 p.m. on
July 29, 2020. Before the Government's response is filed, the parties must meet and
confer by phone regarding this issue, and any response from the Government must
contain an affirmation that the parties have done so. SO ORDERED. (Responses due
by 7/28/2020. Replies due by 7/29/2020.) (Signed by Judge Alison J. Nathan on
7/27/2020) (Inl) (Entered: 07/27/2020)</td></tr><tr><td>07/28/2020</td><td>33</td><td>LETTER RESPONSE to Motion by USA as to Ghislaine Maxwell addressed to Judge
Alison J. Nathan from Alex Rossmiller dated July 28, 2020 re: 29 LETTER MOTION
addressed to Judge Alison J. Nathan from Christian R. Everdell dated July 27, 2020 re:
Proposed Protective Order.. (Attachments: # 1 Exhibit A (proposed protective
order))(Rossmiller, Alex) (Entered: 07/28/2020)</td></tr><tr><td>07/28/2020</td><td>34</td><td>AFFIDAVIT of Alex Rossmiller by USA as to Ghislaine Maxwell. (Rossmiller, Alex)
(Entered: 07/28/2020)</td></tr><tr><td>07/29/2020</td><td>35</td><td>LETTER REPLY TO RESPONSE to Motion by Ghislaine Maxwell addressed to
Judge Alison J. Nathan from Christian R. Everdell dated July 29, 2020 re 29 LETTER
MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell dated July
27, 2020 re: Proposed Protective Order .. (Everdell, Christian) (Entered: 07/29/2020)</td></tr><tr><td>07/30/2020</td><td>36</td><td>PROTECTIVE ORDER as to Ghislaine Maxwell...regarding procedures to be
followed that shall govern the handling of confidential material. SO ORDERED:
(Signed by Judge Alison J. Nathan on 7/30/2020)(bw) (Entered: 07/31/2020)</td></tr><tr><td>07/30/2020</td><td>37</td><td>MEMORANDUM OPINION &amp; ORDER as to Ghislaine Maxwell. Both parties have
asked for the Court to enter a protective order. While they agree on most of the
language, two areas of dispute have emerged. First, Ms. Maxwell seeks language
allowing her to publicly reference alleged victims or witnesses who have spoken on
the public record to the media or in public fora, or in litigation relating to Ms. Maxwell
or Jeffrey Epstein. Second, Ms. Maxwell seeks language restricting potential
Government witnesses and their counsel from using discovery materials for any
purpose other than preparing for the criminal trial in this action. The Government has
proposed contrary language on both of these issues. For the following reasons, the
Court adopts the Government's proposed protective order Under Federal Rule of
Criminal Procedure 16(d)(1), "[a]t any time the court may, for good cause, deny,
restrict, or defer discovery or inspection, or grant other appropriate relief." The good
cause standard "requires courts to balance several interests, including whether
dissemination of the discovery materials inflicts hazard to others... whether the
imposition of the protective order would prejudice the defendant," and "the public's
interest in the information." United States v. Smith, 985 F. Supp. 2d 506, 522
| (S.D.N.Y. 2013). The party seeking to restrict disclosure bears the burden of showing
good cause. Cf. Gambale v. Deutsche Bank AG, 377 F.3d 133, 142 (2d Cir. 2004).
First, the Court finds that the Government has met its burden of showing good cause
with regard to restricting the ability of Ms. Maxwell to publicly reference alleged
victims and witnesses other than those who have publicly identified themselves in this
litigation. As a general matter, it is undisputed that there is a strong and specific
interest in protecting the privacy of alleged victims and witnesses in this case that
supports restricting the disclosure of their identities. Dkt. No. 29 at 3 (acknowledging
that as a baseline the protective order should "prohibit[] Ms. Maxwell, defense
counsel, and others on the defense team from disclosing or disseminating the identity
of any alleged victim or potential witness referenced in the discovery materials"); see
also United States v. Corley, No. 13-cr-48, 2016 U.S. Dist. LEXIS 194426, at *11
(S.D.N.Y. Jan. 15, 2016). The Defense argues this interest is significantly diminished
for individuals who have spoken on the public record about Ms. Maxwell or Jeffrey
Epstein, because they have voluntarily chosen to identify themselves. But not all
accusations or public statements are equal. Deciding to participate in or contribute to a
| criminal investigation or prosecution is a far different matter than simply making a
public statement "relating to" Ms. Maxwell or Jeffrey Epstein, particularly since such a</td></tr></table>

# Case 21-58, Document 23, 03/29/2021, 3065988, Page 10 of 24

<table><tr><th></th><th></th><th>statement might have occurred decades ago and have no relevance to the charges in
this case. These individuals still maintain a significant privacy interest that must be
safeguarded. The exception the Defense seeks is too broad and risks undermining the
protections of the privacy of witnesses and alleged victims that is required by law. In
contrast, the Government's proffered language would allow Ms. Maxwell to publicly
reference individuals who have spoken by name on the record in this case. It also
allows the Defense to "referenc[e] the identities of individuals they believe may be
relevant... to Potential Defense Witnesses and their counsel during the course of the
investigation and preparation of the defense case at trial." Dkt. No. 33-1, 5. This
proposal adequately balances the interests at stake. And as the Government's letter
notes, see Dkt. No. 33 at 4, to the extent that the Defense needs an exception to the
protective order for a specific investigative purpose, they can make applications to the
Court on a case-by-case basis. Second, restrictions on the ability of potential
witnesses and their counsel to use discovery materials for purposes other than
preparing for trial in this case are unwarranted. The request appears unprecedented
despite the fact that there have been many high-profile criminal matters that had
related civil litigation. The Government labors under many restrictions including Rule
6(e) of the Federal Rules of Criminal Procedure, the Privacy Act of 1974, and other
policies of the Department of Justice and the U.S. Attorney's Office for the Southern
District of New York, all of which the Court expects the Government to scrupulously
follow. Furthermore, the Government indicates that it will likely only provide potential
witnesses with materials that those witnesses already have in their possession. See Dkt.
No. 33 at 6. And of course, those witnesses who do testify at trial would be subject to
| examination on the record as to what materials were provided or shown to them by the
Government. Nothing in the Defense's papers explains how its unprecedented
proposed restriction is somehow necessary to ensure a fair trial. For the foregoing
reasons, the Court adopts the Government's proposed protective order, which will be
entered on the docket. This resolves Dkt. No. 29. SO ORDERED. (Signed by Judge
Alison J. Nathan on 7/30/2020)(bw) (Entered: 07/31/2020)</th></tr><tr><td>08/10/2020</td><td>38</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated August 10, 2020 re: Discovery Disclosure and Access. Document filed by
Ghislaine Maxwell. (Everdell, Christian) (Entered: 08/10/2020)</td></tr><tr><td>08/10/2020</td><td>39</td><td>AFFIDAVIT of Christian R. Everdell by Ghislaine Maxwell. (Everdell, Christian)
(Entered: 08/10/2020)</td></tr><tr><td>08/11/2020</td><td>40</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 38 LETTER MOTION
addressed to Judge Alison J. Nathan from Christian R. Everdell dated August 10, 2020
re: Discovery Disclosure and Access. ENDORSEMENT: The Government is hereby
ORDERED to respond to the Defendant's letter motion by Thursday, August 13, 2020.
The Defendant's reply, if any, is due on or before Monday, August 17, 2020.
(Responses due by 8/13/2020. Replies due by 8/17/2020) (Signed by Judge Alison J.
Nathan on 8/11/2020) (ap) (Entered: 08/11/2020)</td></tr><tr><td>08/13/2020</td><td>41</td><td>LETTER RESPONSE in Opposition by USA as to Ghislaine Maxwell addressed to
Judge Alison J. Nathan from Alex Rossmiller dated August 13, 2020 re: 38 LETTER
MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell dated
August 10, 2020 re: Discovery Disclosure and Access .. (Rossmiller, Alex) (Entered:
08/13/2020)</td></tr><tr><td>08/17/2020</td><td>42</td><td>LETTER REPLY TO RESPONSE to Motion by Ghislaine Maxwell addressed to
Judge Alison J. Nathan from Christian R. Everdell dated August 17, 2020 re 38
LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated August 10, 2020 re: Discovery Disclosure and Access.. (Everdell, Christian)
(Entered: 08/17/2020)</td></tr><tr><td>08/17/2020</td><td>43</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Jeffrey S. Pagliuca
dated August 17, 2020 re: Request for Permission to Submit Letter Motion in Excess
of Three Pages. Document filed by Ghislaine Maxwell. (Pagliuca, Jeffrey) (Entered:
08/17/2020)</td></tr><tr><td>08/18/2020</td><td>44</td><td>ORDER as to Ghislaine Maxwell: On August 17, 2020, the Defendant filed a letter
motion seeking a modification of this Court's Protective Order, which the Court
entered on July 30, 2020. Defendant also moves to file that letter motion under seal.
The Governments opposition to Defendant's letter motion is hereby due Friday, August</td></tr></table>

# Case 21-58, Document 23, 03/29/2021, 3065988, Page11 of 24

<table><tr><th></th><th></th><th>21 at 12 p.m. The Defendant's reply is due on Monday, August 24 at 12 p.m. The
parties shall propose redactions to the letter briefing on this issue. Alternatively, the
parties shall provide support and argument for why the letter motions should be sealed
in their entirety. SO ORDERED. (Responses due by 8/21/2020. Replies due by
8/24/2020.) (Signed by Judge Alison J. Nathan on 8/18/2020) (Inl) (Entered:
08/18/2020)</th></tr><tr><td>08/20/2020</td><td>45</td><td>NOTICE OF ATTORNEY APPEARANCE Lara Elizabeth Pomerantz appearing for
USA. (Pomerantz, Lara) (Entered: 08/20/2020)</td></tr><tr><td>08/20/2020</td><td>50</td><td>SEALED DOCUMENT placed in vault. (mhe) (Entered: 08/27/2020)</td></tr><tr><td>08/21/2020</td><td>46</td><td>LETTER RESPONSE in Opposition by USA as to Ghislaine Maxwell addressed to
Judge Alison J. Nathan from Maurene Comey dated August 21, 2020 re: 43 LETTER
MOTION addressed to Judge Alison J. Nathan from Jeffrey S. Pagliuca dated August
17, 2020 re: Request for Permission to Submit Letter Motion in Excess of Three Pages
.. (Rossmiller, Alex) (Entered: 08/21/2020)</td></tr><tr><td>08/21/2020</td><td>47</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
Maurene Comey dated August 21, 2020 re: Proposed redactions to letter briefing, in
response to the Court's Order of August 18, 2020 Document filed by USA.
(Rossmiller, Alex) (Entered: 08/21/2020)</td></tr><tr><td>08/24/2020</td><td>48</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Laura A. Menninger
dated August 24, 2020 re: Request to File Under Seal: Proposed Redactions to Request
to Modify Protective Order and Reply in Support Thereof. Document filed by
Ghislaine Maxwell. (Menninger, Laura) (Entered: 08/24/2020)</td></tr><tr><td>08/25/2020</td><td>49</td><td>MEMORANDUM OPINION AND ORDER: denying without prejudice 38 LETTER
MOTION as to Ghislaine Maxwell (1). On August 10, 2020, the Defendant filed a
letter motion related to two issues. Dkt. No. 38. First, the Defendant seeks an order
directing the Government to disclose to defense counsel immediately the identities of
the three alleged victims referenced in the indictment. Second, the Defendant seeks an
order directing the Bureau of Prisons ("BOP") to release the Defendant into the general
population and to provide her with increased access to the discovery materials. For the
reasons that follow, Defendant's requests are DENIED without prejudice.... [See this
Memorandum Opinion And Order]... III. Conclusion: For the reasons stated above,
Defendant's requests contained in Dkt. No. 38 are DENIED without prejudice.
Following the close of discovery, the parties shall meet and confer on an appropriate
schedule for pre-trial disclosures, including the disclosure of § 3500 material, exhibit
lists, and witness lists, taking into account all relevant factors. The Government is
hereby ORDERED to submit written status updates every 90 days detailing any
material changes to the conditions of Ms. Maxwell's confinement, with particular
emphasis on her access to legal materials and ability to communicate with defense
counsel. SO ORDERED. (Signed by Judge Alison J. Nathan on 8/25/2020) (bw)
(Entered: 08/25/2020)</td></tr><tr><td>09/02/2020</td><td>51</td><td>MEMORANDUMOPINION AND ORDER as to Ghislaine Maxwell: On August 17,
2020, Defendant Ghislaine Maxwell filed a sealed letter motion seeking an Order
modifying the protective order in this case. Specifically, she sought a Court order
allowing her to file under seal in certain civil cases ("Civil Cases") materials
("Documents") that she received in discovery from the Government in this case. She
also sought permission to reference, but not file, other discovery material that the
Government produced in this case. For the reasons that follow, Defendant's requests
are DENIED. SO ORDERED. (Signed by Judge Alison J. Nathan on 9/2/2020)(See
MEMORANDUM OPINION AND ORDER as set forth) (Inl) (Entered: 09/02/2020)</td></tr><tr><td>09/02/2020</td><td>52</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan, from Jeffrey S.
Pagliuca dated 8/17/2020 re: Defense counsel writes with redacted request to modify
protective order. (ap) (Entered: 09/02/2020)</td></tr><tr><td>09/04/2020</td><td>55</td><td>NOTICE OF APPEAL by Ghislaine Maxwell from 51 Memorandum &amp; Opinion.
Filing fee $ 505.00, receipt number 465401266036. (tp) (Entered: 09/09/2020)</td></tr><tr><td>09/08/2020</td><td>53</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan dated 8/24/2020
re: Proposed Redactions to Request to Modify Protective Order. (jbo) (Entered:
09/08/2020)</td></tr></table>

# Case 21-58, Document 23, 03/29/2021, 3065988, Page 12 of 24

<table><tr><th>09/08/2020</th><th>54</th><th>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan dated 8/24/2020
re: Reply in Support of Request to Modify Protective Order. (jbo) (Entered:
09/08/2020)</th></tr><tr><td>09/09/2020</td><td></td><td>Transmission of Notice of Appeal and Certified Copy of Docket Sheet as to Ghislaine
Maxwell to US Court of Appeals re: 55 Notice of Appeal. (tp) (Entered: 09/09/2020)</td></tr><tr><td>09/09/2020</td><td></td><td>Appeal Record Sent to USCA (Electronic File). Certified Indexed record on Appeal
Electronic Files as to Ghislaine Maxwell re: 55 Notice of Appeal were transmitted to
the U.S. Court of Appeals. (tp) (Entered: 09/09/2020)</td></tr><tr><td>09/10/2020</td><td>56</td><td>SEALED DOCUMENT placed in vault. (dn) (Entered: 09/11/2020)</td></tr><tr><td>09/10/2020</td><td>57</td><td>SEALED DOCUMENT placed in vault. (dn) (Entered: 09/11/2020)</td></tr><tr><td>09/24/2020</td><td>58</td><td>SEALED DOCUMENT placed in vault. (mhe) (Entered: 09/24/2020)</td></tr><tr><td>10/05/2020</td><td>59</td><td>NOTICE OF ATTORNEY APPEARANCE: Bobbi C Sternheim appearing for
Ghislaine Maxwell. Appearance Type: Retained. (Sternheim, Bobbi) (Entered:
10/05/2020)</td></tr><tr><td>10/06/2020</td><td>60</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated October 6, 2020 re:
Request to Delay Disclosure Document filed by USA. (Comey, Maurene) (Entered:
10/06/2020)</td></tr><tr><td>10/06/2020</td><td>61</td><td>AFFIDAVIT of Maurene Comey by USA as to Ghislaine Maxwell. (Comey, Maurene)
(Entered: 10/06/2020)</td></tr><tr><td>10/07/2020</td><td>62</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 60 Accordingly, the
Government respectfully requests that the Court approve the Government's request to
delay disclosure of these Materials...ENDORSEMENT...The Defendant shall file any
opposition to the Government's request by October 14, 2020. The Government's reply,
if any, is due by October 20, 2020. SO ORDERED. (Government Replies due by
10/20/2020., Defendant Responses due by 10/14/2020) (Signed by Judge Alison J.
Nathan on 10/7/20)(jw) (Entered: 10/07/2020)</td></tr><tr><td>10/07/2020</td><td>63</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAs Maurene Comey, Alison Moe, and Lara Pomerantz dated October 7, 2020 re:
Review of Investigative Files from Other Offices and Agencies Document filed by
USA. (Comey, Maurene) (Entered: 10/07/2020)</td></tr><tr><td>10/14/2020</td><td>64</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated October 14, 2020 re: Response to 60 LETTER addressed to Judge
Alison J. Nathan from USA dated October 6, 2020 re: Request to Delay Disclosure.
(Everdell, Christian) (Entered: 10/14/2020)</td></tr><tr><td>10/20/2020</td><td>65</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated October 20, 2020 re:
Reply Letter in Further Support of Request to Delay Disclosure Document filed by
USA. (Comey, Maurene) (Entered: 10/20/2020)</td></tr><tr><td>10/23/2020</td><td>66</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Jeffrey S.
Pagliuca dated October 23, 2020 re: Response to the Governments October 7, 2020
letter (Pagliuca, Jeffrey) (Entered: 10/23/2020)</td></tr><tr><td>10/30/2020</td><td>67</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAs Maurene Comey, Alison Moe, and Lara Pomerantz dated October 30, 2020 re:
Reply to Defense's October 23, 2020 Letter Document filed by USA. (Comey,
Maurene) (Entered: 10/30/2020)</td></tr><tr><td>11/05/2020</td><td>68</td><td>ORDER as to Ghislaine Maxwell: This Order is entered, pursuant to Federal Rule of
Criminal Procedure 5(f) and the Due Process Protections Act, Pub. L. No 116182, 134
Stat. 894 (Oct. 21, 2020), to confirm the Government's disclosure obligations under
Brady v. Maryland, 373 U.S. 83 (1963), and its progeny, and to summarize the
possible consequences of violating those obligations. (Signed by Judge Alison J.
Nathan on 11/5/2020) (See ORDER set forth) (ap) (Entered: 11/05/2020)</td></tr></table>

# Case 21-58, Document 23, 03/29/2021, 3065988, Page13 of 24

<table><tr><th>11/06/2020</th><th>69</th><th>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated November 6, 2020
re: Request to Extend Discovery Deadline for Portion of Electronic Discovery
Document filed by USA. (Comey, Maurene) (Entered: 11/06/2020)</th></tr><tr><td>11/06/2020</td><td>70</td><td>AFFIDAVIT of Maurene Comey by USA as to Ghislaine Maxwell. (Comey, Maurene)
(Entered: 11/06/2020)</td></tr><tr><td>11/09/2020</td><td>71</td><td>MANDATE of USCA (Certified Copy) as to Ghislaine Maxwell re: 55 Notice of
Appeal. USCA Case Number 20-3061-cr. UPON DUE CONSIDERATION
WHEREOF, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that the
motion to consolidate is DENIED and the appeal is DISMISSED for want of
jurisdiction.. Catherine O'Hagan Wolfe, Clerk USCA for the Second Circuit. Issued As
Mandate: 11/09/2020. (nd) (Entered: 11/09/2020)</td></tr><tr><td>11/09/2020</td><td>72</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on 69 LETTER by USA as to
Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene
Comey, Alison Moe, and Lara Pomerantz dated November 6, 2020 re: Request to
Extend Discovery Deadline for Portion of Electronic Discovery. ENDORSEMENT:
The Court hereby extends the deadline for the Government's production of electronic
discovery from November 9, 2020 to November 23, 2020. The Court also grants the
parties' request for an extension of the motions deadlines as follows: the Defendant's
motions are due by January 11, 2021, the Government's responses are due by February
12, 2021, and any replies are due by February 19, 2021. SO ORDERED. (Discovery
due by 11/23/2020. Motions due by 1/11/2021. Responses due by 2/12/2021. Replies
due by 2/19/2021.) (Signed by Judge Alison J. Nathan on 11/9/2020) (Inl) (Entered:
11/10/2020)</td></tr><tr><td>11/18/2020</td><td>73</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 60 Letter filed by USA as
to Ghislaine Maxwell re: The Government respectfully requests that the Court approve
the Government's request to delay disclosure of these
Materials...ENDORSEMENT...There is no dispute that the materials referenced in the
Government's letter will be turned over to the defense. The Government has indicated
that it will do so. The only dispute, then, relates to the timing of such disclosure. See
Dkt. Nos. 64, 65. Because the Government has articulated plausible reasons for some
delay of disclosure, see Dkt. No. 65 at 4, the Court grants the Government's request to
delay disclosure. However, the Governments proposal to delay disclosure until 8
weeks in advance of trial is insufficient. In order to ensure that the defense can
adequately prepare for trial, the Government shall produce the referenced materials,
which are not voluminous, to the defense by March 12, 2021. Disclosure of the
materials will of course be subject to the protective order entered by the Court, see
Dkt. No. 36. (Government Responses due by 3/12/2021) (Signed by Judge Alison J.
Nathan on 11/18/20)(jw) (Entered: 11/18/2020)</td></tr><tr><td>11/23/2020</td><td>74</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated November 23, 2020
re: Update Regarding Conditions of Confinement Document filed by USA. (Comey,
Maurene) (Entered: 11/23/2020)</td></tr><tr><td>11/24/2020</td><td>75</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C.
Sternheim dated 11/24/2020 re: Response to 90-day MDC conditions report
(Sternheim, Bobbi) (Entered: 11/24/2020)</td></tr><tr><td>11/24/2020</td><td>76</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 75 LETTER by Ghislaine
Maxwell addressed to Judge Alison J. Nathan from Bobbi C. Sternheim dated
11/24/2020 re: Response to 90-day MDC conditions report. ENDORSEMENT: The
parties are hereby ORDERED to meet and confer regarding Defendant's request that
Warden Heriberto Tellez directly address Defendant's concerns regarding the
conditions of her detention. The parties shall jointly submit a status update within one
week of this Order. (Signed by Judge Alison J. Nathan on 11/24/2020) (ap) (Entered:
11/24/2020)</td></tr><tr><td>12/01/2020</td><td>77</td><td>ORDER as to Ghislaine Maxwell. On November 25, 2020, the Defendant filed a letter
request under seal. On November 30, 2020, she filed a second letter request in which
she proposed redactions on both letters. The Government is hereby ORDERED to
respond to the Defendant's November 25, 2020 letter request and to the request for
proposed redactions by no later than December 2, 2020. The letters shall be</td></tr></table>

# Case 21-58, Document 23, 03/29/2021, 3065988, Page14 of 24

<table><tr><th></th><th></th><th>temporarily sealed while the Court resolves the redaction request. SO ORDERED.
(Signed by Judge Alison J. Nathan on 12/1/2020)(bw) (Entered: 12/01/2020)</th></tr><tr><td>12/01/2020</td><td>78</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated December 1, 2020
re: Joint Letter regarding Conditions of Confinement Document filed by USA.
(Pomerantz, Lara) (Entered: 12/01/2020)</td></tr><tr><td>12/02/2020</td><td>79</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 78 LETTER by USA
addressed to Judge Alison J. Nathan from AUSAS Maurene Comey, Alison Moe, and
Lara Pomerantz dated December 1, 2020 re: Joint Letter regarding Conditions of
Confinement. ENDORSEMENT: MDC legal counsel shall submit their letter to the
Court by December 4, 2020. Upon review of that letter, the Court will determine
whether any additional information is required, either orally or in writing. SO
ORDERED. (Signed by Judge Alison J. Nathan on 12/2/2020)(bw) (Entered:
12/02/2020)</td></tr><tr><td>12/02/2020</td><td>80</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated December 2, 2020
re: Defense Requests for Sealing Document filed by USA. (Comey, Maurene)
(Entered: 12/02/2020)</td></tr><tr><td>12/03/2020</td><td>81</td><td>ORDER as to Ghislaine Maxwell. On November 25, 2020, counsel for Defendant
Ghislaine Maxwell filed a letter request seeking an in camera conference for the
presentation of a renewed motion for release on bail and a request to seal the
November 25, 2020 letter in its entirety. The Court required justification for the
sealing request. On November 30, 2020, the defense counsel filed a second letter no
longer fully pressing the unsupported request to file the letter entirely under seal and
instead proposing redactions to both the November 25th and November 30th letters.
The Government has indicated that it does not oppose the redactions. Dkt. No. 80.
After due consideration, the Court will adopt the Defendant's proposed redactions,
which are consented to by the Government. The Court's decision is guided by the
three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of
Onondaga, 435 F.3d 110 (2d Cir. 2006). Under this test, the Court must: (i) determine
whether the documents in question are "judicial documents;" (ii) assess the weight of
the common law presumption of access to the materials; and (iii) balance competing
considerations against the presumption of access. Id. at 11920. "Such countervailing
factors include but are not limited to 'the danger of impairing law enforcement or
judicial efficiency' and 'the privacy interests of those resisting disclosure."" Id. at 120
(quoting United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995) ("Amodeo II")).
The proposed redactions satisfy this test. First, the Court finds that the Defendant's
letter motions are "relevant to the performance of the judicial function and useful in
the judicial process," thereby qualifying as a "judicial document" for purposes of the
first element of the Lugosch test. United States v. Amodeo ("Amodeo I"), 44 F.3d 141,
145 (2d Cir. 1995). And while the Court assumes that the common law presumption of
access attaches, in balancing competing considerations against the presumption of
access, the Court finds that the arguments the Defendant has put forthincluding, most
notably, the privacy interests of the individuals referenced in the lettersfavor her
proposed and tailored redactions. The Defendant is hereby ORDERED to docket the
redacted versions of the two letters by December 4, 2020. For the reasons outlined in
the Government's letter dated December 2, 2020, Dkt. No. 80, the Court DENIES the
Defendant's request for an in camera conference. In order to protect the privacy
interests referenced in the Defendant's November 25, 2020 letter, the Court will permit
the Defendant to make her submission in writing and to propose narrowly tailored
redactions. The parties are hereby ORDERED to meet and confer and to jointly
prepare a briefing schedule for the Defendant's forthcoming renewed motion for
release on bail. SO ORDERED. (Signed by Judge Alison J. Nathan on 12/3/2020)(bw)
(Entered: 12/03/2020)</td></tr><tr><td>12/03/2020</td><td>82</td><td>SEALED DOCUMENT placed in vault. (jus) (Entered: 12/03/2020)</td></tr><tr><td>12/03/2020</td><td>83</td><td>SEALED DOCUMENT placed in vault. (jus) (Entered: 12/03/2020)</td></tr><tr><td>12/03/2020</td><td>84</td><td>SEALED DOCUMENT placed in vault. (jus) (Entered: 12/03/2020)</td></tr></table>

# Case 21-58, Document 23, 03/29/2021, 3065988, Page 15 of 24

<table><tr><th>12/04/2020</th><th>85</th><th>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated December 4, 2020 re: Briefing Schedule (Everdell, Christian) (Entered:
12/04/2020)</th></tr><tr><td>12/04/2020</td><td>86</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated 11/25/2020 re: Sealing (Everdell, Christian) (Entered: 12/04/2020)</td></tr><tr><td>12/04/2020</td><td>87</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
| Everdell dated 11/30/2020 re: Sealing (Everdell, Christian) (Entered: 12/04/2020)</td></tr><tr><td>12/07/2020</td><td>88</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Sophia
Papapetru and John Wallace dated 12/4/20 re: This letter is written in response to your
order dated December 2, 2020, concerning Ghislaine Maxwell, Reg. 02879-509., an
inmate currently confined at the Metropolitan Detention center in Brooklyn, New
York. You expressed various concerns regarding Ms. Maxwells confinement and
well-being. (jw) (Entered: 12/07/2020)</td></tr><tr><td>12/07/2020</td><td>89</td><td>ORDER as to Ghislaine Maxwell re: 85 Letter filed by Ghislaine Maxwell. The Court
is in receipt of the Defendant's December 4, 2020 letter, Dkt. No. 85, and hereby sets
the following schedule: The Defendants submission is due December 8, 2020; The
Government's response is due December 16, 2020; The Defendant's reply is due
December 18, 2020. After reviewing these submissions, the Court will determine
whether a hearing on the renewed bail motion is necessary. The Court grants the
Defendants request that the Government shall file its submission under seal with
proposed redactions. Any objections to proposed redactions are due within 24 hours
after any brief has been filed. Finally, the Defendant is granted leave to file a motion
not to exceed 40 pages. The Governments response shall also be limited to 40 pages.
The Defendant's reply shall not exceed 10 pages (Defendant submission due by
12/8/2020., Defendant Replies due by 12/18/2020., Government Responses due by
12/16/2020) (Signed by Judge Alison J. Nathan on 12/7/20)(jw) (Entered: 12/07/2020)</td></tr><tr><td>12/07/2020</td><td>90</td><td>ENDORSED LETTER as to Ghislaine Maxwell addressed to Judge Alison J. Nathan
from Mark S. Cohen and Christian R. Everdell dated 11/25/20 re: On behalf of my
client, Ghislaine Maxwell, we plan to file a Renewed Motion for Release on Bail (the
"Motion") and respectfully request an in camera conference, with all counsel present,
to address the appropriate procedures for the filing and consideration of the Motion.
For the reasons explained below, we intend to request, pursuant to Fed. R. Crim. P.
49.1(d), that the Court permit the filing of portions of the Motion and certain
supporting materials under seal and require that any responsive materials be filed
under seal....ENDORSEMENT: The Court sees no basis for the sealing of this letter.
On or before December 2, 2020, Defendant shall justify why this letter should be
sealed (or redacted). Alternatively, the Defendant may file the letter on the public
docket by that date. The Court will take no action on the request pending resolution of
the initial sealing question. The Defendant's letter and this memorandum endorsement
will be temporarily sealed pending resolution of the sealing request. (Signed by Judge
Alison J. Nathan on 11/25/20)(jw) (Entered: 12/07/2020)</td></tr><tr><td>12/07/2020</td><td>91</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C.
Sternheim dated 12/07/2020 re: Response to MDC Report to Court re: conditions
(Sternheim, Bobbi) (Entered: 12/07/2020)</td></tr><tr><td>12/08/2020</td><td>92</td><td>ORDER as to Ghislaine Maxwell: On December 4, 2020, the Court received a letter
from MDC legal counsel responding to the concerns that the Defendant raised in her
November 24, 2020 letter. See Dkt. Nos. 75, 88; see also Dkt. No. 78. The Defendant
responded to the MDC legal counsel's letter on December 7, 2020, reiterating her
request that the Court summon Warden Heriberto Tellez to personally respond to
questions from the Court regarding the Defendant's conditions of confinement. See
Dkt. No. 91. Having carefully reviewed the parties' submissions, along with the MDC
legal counsel's December 4, 2020 letter, the Court DENIES the Defendant's request to
summon the Warden to personally appear and respond to questions. This resolves Dkt.
No. 75. Notwithstanding this, as originally provided in Dkt. No. 49, the Government
shall continue to submit written status updates detailing any material changes to the
conditions of Ms. Maxwell's confinement, with particular emphasis on her access to
legal materials, including legal mail and email, and her ability to communicate with
defense counsel. The updates shall also include information on the frequency of
searches of the Defendant. The Court hereby ORDERS the Government to submit
these written updates every 60 days. Furthermore, the Government shall take all</td></tr></table>

# Case 21-58, Document 23, 03/29/2021, 3065988, Page16 of 24

<table><tr><th></th><th></th><th>necessary steps to ensure that the Defendant continues to receive adequate access to
her legal materials and her ability to communicate with defense counsel. (Signed by
Judge Alison J. Nathan on 12/8/2020) (ap) (Entered: 12/08/2020)</th></tr><tr><td>12/10/2020</td><td>93</td><td>TRANSCRIPT of Proceedings as to Ghislaine Maxwell re: Conference held on
7/14/2020 before Judge Alison J. Nathan. Court Reporter/Transcriber: Kristen
Carannante, (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 12/31/2020. Redacted Transcript Deadline set for 1/11/2021. Release of
Transcript Restriction set for 3/10/2021. (McGuirk, Kelly) (Entered: 12/10/2020)</td></tr><tr><td>12/10/2020</td><td>94</td><td>NOTICE OF FILING OF OFFICIAL TRANSCRIPT as to Ghislaine Maxwell. Notice
is hereby given that an official transcript of a Conference proceeding held on
7/14/2020 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.... (McGuirk, Kelly) (Entered: 12/10/2020)</td></tr><tr><td>12/14/2020</td><td>95</td><td>ORDER as to Ghislaine Maxwell: On December 8, 2020, Defendant Ghislaine
Maxwell filed her renewed application for bail under seal with proposed redactions, in
accordance with this Court's December 7, 2020 Order, see Dkt. No. 89. The
Government did not file any opposition to the Defendant's proposed redactions. After
due consideration, the Court will adopt the Defendant's proposed redactions. The
Court's decision to adopt those redactions is guided by the three-part test articulated
by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir.
2006). Under this test, the Court must: (i) determine whether the documents in
question are "judicial documents;" (ii) assess the weight of the common law
presumption of access to the materials; and (iii) balance competing considerations
against the presumption of access. Id. at 11920. "Such countervailing factors include
but are not limited to the danger of impairing law enforcement or judicial efficiency'
and 'the privacy interests of those resisting disclosure." Id. at 120 (quoting United
States v. Amodeo, 71 F.3d 1044, 1048 (2d Cir. 1995) ("Amodeo II")). The proposed
redactions satisfy this test. The Court finds that Defendant's letter motions are
"relevant to the performance of the judicial function and useful in the judicial process,'
thereby qualifying as a "judicial document" for purposes of the first element of the
Lugosch test. United States v. Amodeo ("Amodeo I"), 44 F.3d 141, 145 (2d Cir. 1995).
And the Court also finds that the common law presumption of access attaches. Id. at
146; see also Nixon v. Warner Comme'ns, Inc., 435 U.S. 589, 602 (1978).
Nevertheless, in balancing competing considerations against the presumption of
access, the Court finds that the redactions are narrowly tailored to properly guard the
privacy interests of the individuals referenced in the Defendant's submission and in the
corresponding exhibits The Defendant is hereby ORDERED to docket the redacted
documents and corresponding exhibits. (Signed by Judge Alison J. Nathan on
12/14/2020) (ap) (Entered: 12/14/2020)</td></tr><tr><td>12/14/2020</td><td>96</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated December 8, 2020 re: Cover Letter for Renewed Bail Application
(Everdell, Christian) (Entered: 12/14/2020)</td></tr><tr><td>12/14/2020</td><td>97</td><td>MEMORANDUM OF LAW in Support by Ghislaine Maxwell re: Renewed Motion
for Bail. (Attachments: # 1 Exhibit A, #2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5
Exhibit E, #6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, #2 Exhibit I, # 10 Exhibit J, #
11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16
Exhibit P, #17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit
U, #22 Exhibit V, # 23 Exhibit W, # 24 Exhibit X)(Everdell, Christian) (Entered:
12/14/2020)</td></tr><tr><td>12/17/2020</td><td>98</td><td>NOTICE OF ATTORNEY APPEARANCE Andrew Rohrbach appearing for USA.
(Rohrbach, Andrew) (Entered: 12/17/2020)</td></tr><tr><td>12/18/2020</td><td>99</td><td>ORDER as to Ghislaine Maxwell: On December 16, 2020, the Government filed its
opposition to Defendant Ghislaine Maxwell's renewed application for bail. In
accordance with this Court's December 7, 2020 Order, see Dkt. No. 89, the
Government filed its materials under seal and proposed narrowly tailored redactions on</td></tr></table>

# Case 21-58, Document 23, 03/29/2021, 3065988, Page17 of 24

<table><tr><th></th><th></th><th>those materials. The Defendant did not file any opposition to the Government's
proposed redactions. The Court will adopt the Government's proposed redactions after
applying the three-part test articulated by the Second Circuit in Lugosch v. Pyramid
Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Under this test, the Court must: (i)
determine whether the documents in question are "judicial documents;" (ii) assess the
weight of the common law presumption access to the materials; and (iii) balance
competing considerations against the presumption of access. Id. at 11920. "Such
countervailing factors include but are not limited to 'the danger of impairing law
enforcement or judicial efficiency' and 'the privacy interests of those resisting
disclosure."" Id. at 120 (quoting United States v. Amodeo ("Amodeo II"), 71 F.3d
1044, 1050 (2d Cir. 1995)). The proposed redactions satisfy this test. The Court finds
that the Governments submissions are "relevant to the performance of the judicial
function and useful in the judicial process," thereby qualifying as a "judicial
document" for purposes of the first element of the Lugosch test. United States v.
Amodeo ("Amodeo I"), 44 F.3d 141, 145 (2d Cir. 1995). And the Court also finds that
the common law presumption of access attaches. Id. at 146; see also Nixon v. Warner
Comme'ns, Inc., 435 U.S. 589, 602 (1978). Nevertheless, the proposed redactions are
narrowly tailored to serve substantial interests, including, most importantly, third
parties' personal privacy interests. See Under Seal v. Under Seal, 273 F. Supp. 3d 460
467 (S.D.N.Y.2017). The Government is hereby ORDERED to docket the redacted
documents and corresponding exhibits by no later than December 18, 2 (Signed by
Judge Alison J. Nathan on 12/18/2020) (ap) (Entered: 12/18/2020)</th></tr><tr><td>12/18/2020</td><td>100</td><td>MEMORANDUM OF LAW in Opposition by USA as to Ghislaine Maxwell Renewed
Bail Motion. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Comey, Maurene) (Entered:
12/18/2020)</td></tr><tr><td>12/23/2020</td><td>101</td><td>ORDER as to Ghislaine Maxwell: On December 18, 2020, the Defendant filed her
reply to the Government's opposition to her renewed application for bail. In
accordance with this Court's December 7, 2020 Order, see Dkt. No. 89, she filed these
materials under seal and proposed narrowly tailored redactions on those materials. The
Government did not file any opposition to the Defendant's proposed redactions. The
Court will adopt the Defendant's proposed redactions after applying the three-part test
articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d
110 (2d Cir. 2006). Under this test, the Court must: (i) determine whether the
documents in question are "judicial documents;" (ii) assess the weight of the common
law presumption of access to the materials; and (iii) balance competing considerations
against the presumption of access. Id. at 11920. "Such countervailing factors include
but are not limited to 'the danger of impairing law enforcement or judicial efficiency'
and 'the privacy interests of those resisting disclosure." Id. at 120 (quoting United
States v. Amodeo ("Amodeo II"), 71 F.3d 1044, 1050 (2d Cir. 1995)). The proposed
redactions satisfy this test. The Court finds that the Defendant's submissions are
"relevant to the performance of the judicial function and useful in the judicial process,'
thereby qualifying as a "judicial document" for purposes of the first element of the
Lugosch test. United States v. Amodeo ("Amodeo Î"), 44 F.3d 141, 145 (2d Cir. 1995).
And the Court also finds that the common law presumption of access attaches. Id. at
146; see also Nixon v. Warner Comme'ns, Inc., 435 U.S. 589, 602 (1978). As with the
redactions to her renewed motion for bail, the proposed redactions here are narrowly
tailored to serve substantial interests, including, most importantly, third parties
personal privacy interests. See Under Seal v. Under Seal, 273 F. Supp. 3d 460, 467
|(S.D.N.Y. 2017). See also Dkt. No. 95. The Defendant is hereby ORDERED to docket
the redacted documents and corresponding exhibits by no later than December 23,
2020. SO ORDERED. (Signed by Judge Alison J. Nathan on 12/23/2020) (Inl)
(Entered: 12/23/2020)</td></tr><tr><td>12/23/2020</td><td>102</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated December 18, 2020 re: Cover Letter for Reply Memorandum for
Renewed Bail Application (Everdell, Christian) (Entered: 12/23/2020)</td></tr><tr><td>12/23/2020</td><td>103</td><td>REPLY MEMORANDUM OF LAW in Support by Ghislaine Maxwell re: Renewed
Motion for Bail. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Everdell, Christian)
(Entered: 12/23/2020)</td></tr><tr><td>12/28/2020</td><td>104</td><td>ORDER as to Ghislaine Maxwell. On December 8, 2020, Defendant Ghislaine
Maxwell filed a renewed motion for releaseon bail. Dkt No. 97. In an Opinion and
Order concurrently filed under temporary seal, the Court DENIES the Defendant's</td></tr></table>

# Case 21-58, Document 23, 03/29/2021, 3065988, Page18 of 24

<table><tr><th></th><th></th><th>motion. In light of the fact that the Opinion includes potentially confidential
information that should not be filed on the public docket, the Court will permit the
parties 48 hours to propose any redactions to the Courts Opinion and Order and to
justify those redactions by reference tothe Second Circuits decision in Lugosch v.
Pyramid Co. of Onondaga, 435 F.3d 110(2d Cir. 2006). After determining which, if
any, portions of the Opinion and Order should be redacted, the Court will file the
Opinion and Order on the public docket. As a result, the Court concludes that the
Government has met its burden of persuasion that the Defendant poses a flight risk and
that pretrial detention continues to be warranted. On or before December 30, 2020, the
parties are ORDERED to submit a joint letter indicating whether they propose any
redactions and the justification for any such proposal. This resolves Dkt No. 97.
(Signed by Judge Alison J. Nathan on 12/28/20)(jw) (Entered: 12/28/2020)</th></tr><tr><td>12/30/2020</td><td>105</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated December 30, 2020
re: Joint Letter re December 28, 2020 Opinion and Order Document filed by USA.
(Comey, Maurene) (Entered: 12/30/2020)</td></tr><tr><td>12/30/2020</td><td>106</td><td>OPINION AND ORDER as to Ghislaine Maxwell. Defendant Ghislaine Maxwell has
been indicted by a grand jury on charges of conspiracy to entice minors to travel to
engage in illegal sex acts, in violation of 18 U.S.C. § 371; enticing a minor to travel to
engage in illegal sex acts, in violation of 18 U.S.C. §§ 2422 and 2; conspiracy to
transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371;
transporting minors to participate in illegal sex acts, in violation of 18 U.S.C. §§ 2423
and 2; and two charges of perjury, in violation of 18 U.S.C. § 1623. The Court held a
lengthy bail hearing on July 14, 2020. After extensive briefing and argument at the
hearing, the Court concluded that the Defendant was a clear risk of flight and that no
conditions or combination of conditions would ensure her appearance. Defendant
Ghislaine Maxwells renewed motion for release on bail, Dkt. No. 97, is DENIED.
(Signed by Judge Alison J. Nathan on 12/28/20)(jw) (Entered: 12/30/2020)</td></tr><tr><td>12/31/2020</td><td>107</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated December 31, 2020 re: Extension of Time Document filed by Ghislaine
Maxwell. (Everdell, Christian) (Entered: 12/31/2020)</td></tr><tr><td>01/05/2021</td><td>108</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell (1) on 107 LETTER MOTION
addressed to Judge Alison J. Nathan from Christian R. Everdell dated December 31,
2020 re: Extension of Time. ENDORSEMENT: SO ORDERED. (Signed by Judge
Alison J. Nathan on 1/5/2021) (ap) (Entered: 01/05/2021)</td></tr><tr><td>01/05/2021</td><td></td><td>Set/Reset Deadlines as to Ghislaine Maxwell: Motions due by 1/25/2021. Responses
| due by 2/26/2021. Replies due by 3/5/2021. (ap) (Entered: 01/05/2021)</td></tr><tr><td>01/08/2021</td><td>109</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated January 8, 2021 re: Extension of Time to File Notice of Appeal. Document filed
by Ghislaine Maxwell. (Everdell, Christian) (Entered: 01/08/2021)</td></tr><tr><td>01/11/2021</td><td>110</td><td>SEALED DOCUMENT placed in vault. (jus) (Entered: 01/11/2021)</td></tr><tr><td>01/11/2021</td><td>111</td><td>SEALED DOCUMENT placed in vault. (jus) (Entered: 01/11/2021)</td></tr><tr><td>01/11/2021</td><td>112</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell (1) denying 109 LETTER
MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell dated
January 8, 2021 re: Extension of Time to File Notice of Appeal. ENDORSEMENT:
The request is denied. Good cause for an extension of time to file a notice of appeal
has not been provided. SO ORDERED. (Signed by Judge Alison J. Nathan on
1/11/2021) (Inl) (Entered: 01/11/2021)</td></tr><tr><td>01/11/2021</td><td>113</td><td>NOTICE OF APPEAL by Ghislaine Maxwell from 104 Order. (nd) (Entered:
01/12/2021)</td></tr><tr><td>01/11/2021</td><td></td><td>Appeal Remark as to re: 113 Notice of Appeal by Ghislaine Maxwell. $505.00 Appeal
filing fee due. (nd) (Entered: 01/12/2021)</td></tr><tr><td>01/12/2021</td><td></td><td>Transmission of Notice of Appeal and Certified Copy of Docket Sheet as to Ghislaine
| Maxwell to US Court of Appeals re: 113 Notice of Appeal. (nd) (Entered: 01/12/2021)</td></tr></table>

# Case 21-58, Document 23, 03/29/2021, 3065988, Page 19 of 24

<table><tr><th>01/12/2021</th><th></th><th>Appeal Record Sent to USCA (Electronic File). Certified Indexed record on Appeal
Electronic Files as to Ghislaine Maxwell re: 113 Notice of Appeal were transmitted to
the U.S. Court of Appeals. (nd) (Entered: 01/12/2021)</th></tr><tr><td>01/13/2021</td><td>114</td><td>INTERNET CITATION NOTE as to Ghislaine Maxwell: Material from decision with
Internet citation re: 106 Memorandum &amp; Opinion. (sjo) (Entered: 01/13/2021)</td></tr><tr><td>01/14/2021</td><td>115</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated January 14, 2021 re: Laptop Access (Everdell, Christian) (Entered:
01/14/2021)</td></tr><tr><td>01/15/2021</td><td>116</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on 115 LETTER by Ghislaine
Maxwell addressed to Judge Alison J. Nathan from Christian R. Everdell dated
|January 14, 2021 re: Laptop Access. ENDORSEMENT: The unobjected-to request is
GRANTED. The Bureau of Prisons is ORDERED to give the Defendant access to the
laptop computer on weekends and holidays during the hours that she is permitted to
review discovery. SO ORDERED. (Signed by Judge Alison J. Nathan on 1/15/2021)
(Inl) (Entered: 01/15/2021)</td></tr><tr><td>01/15/2021</td><td></td><td>USCA Case Number 21-0058 from the U.S. Court of Appeals, 2nd Circ. as to
Ghislaine Maxwell, assigned to 113 Notice of Appeal filed by Ghislaine Maxwell. (nd)
(Entered: 01/15/2021)</td></tr><tr><td>01/15/2021</td><td></td><td>USCA Appeal Fees received $ 505.00, receipt number 465401271727 as to Ghislaine
Maxwell on 01/15/2021 re: 113 Notice of Appeal filed by Ghislaine Maxwell. (nd)
(Entered: 01/15/2021)</td></tr><tr><td>01/25/2021</td><td>117</td><td>ORDER as to Ghislaine Maxwell: On January 25, 2021, the Court received by email
the attached letter from the Bureau of Prisons ("BOP"). In the letter, the BOP requests
that the Court vacate its January 15, 2021 Order, Dkt. No. 116, which directed the
BOP to give the Defendant access to her Government provided laptop computer on
weekends and holidays during the hours that she is permitted to review discovery. The
Defendant and the Government may respond to the BOP's letter within one week of
this Order. (Signed by Judge Alison J. Nathan on 1/25/2021) (ap) (Entered:
01/25/2021)</td></tr><tr><td>01/25/2021</td><td>118</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Mark S.
Cohen dated January 25, 2021 re: Pretrial Motions (Cohen, Mark) (Entered:
01/25/2021)</td></tr><tr><td>01/25/2021</td><td>119</td><td>MOTION for Separate Trial on Counts Ghislaine Maxwell (1) Count 5s-6s,5-6.
Document filed by Ghislaine Maxwell. (Pagliuca, Jeffrey) (Entered: 01/25/2021)</td></tr><tr><td>01/25/2021</td><td>120</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 119 MOTION for Separate
Trial on Counts Ghislaine Maxwell (1) Count 5s-6s,5-6 .. (Pagliuca, Jeffrey)
|(Entered: 01/25/2021)</td></tr><tr><td>01/25/2021</td><td>121</td><td>MOTION to Dismiss Either Count One Or Count Three of the Superseding Indictment
as Multiplicitous. Document filed by Ghislaine Maxwell. (Pagliuca, Jeffrey) (Entered:
01/25/2021)</td></tr><tr><td>01/25/2021</td><td>122</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 121 MOTION to Dismiss
Either Count One Or Count Three of the Superseding Indictment as Multiplicitous..
(Pagliuca, Jeffrey) (Entered: 01/25/2021)</td></tr><tr><td>01/25/2021</td><td>123</td><td>MOTION to Dismiss Counts One through Four of the Superseding Indictment for
Lack of Specificity. Document filed by Ghislaine Maxwell. (Pagliuca, Jeffrey)
(Entered: 01/25/2021)</td></tr><tr><td>01/25/2021</td><td>124</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 123 MOTION to Dismiss
Counts One through Four of the Superseding Indictment for Lack of Specificity..
(Pagliuca, Jeffrey) (Entered: 01/25/2021)</td></tr><tr><td>01/25/2021</td><td>125</td><td>MOTION to Dismiss the Superseding Indictment as it was Obtained in Violation of
the Sixth Amendment. Document filed by Ghislaine Maxwell. (Cohen, Mark) (Entered:
01/25/2021)</td></tr><tr><td>01/25/2021</td><td>126</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 125 MOTION to Dismiss the
Superseding Indictment as it was Obtained in Violation of the Sixth Amendment..</td></tr></table>

# Case 21-58, Document 23, 03/29/2021, 3065988, Page20 of 24

<table><tr><th></th><th></th><th>(Cohen, Mark) (Entered: 01/25/2021)</th></tr><tr><td>01/26/2021</td><td>127</td><td>ORDER as to Ghislaine Maxwell: On January 25, 2021, the Defendant filed twelve
pre-trial motions. Because there is a request to redact sensitive or confidential
information, several of the motions have been filed under temporary seal. The
Government may respond to the Defendant's proposed redactions within two days of
this Order. (Signed by Judge Alison J. Nathan on 1/26/2021) (ap) (Entered:
01/26/2021)</td></tr><tr><td>01/28/2021</td><td>128</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated
January 28, 2021 re: Defendant's Proposed Redactions to Pre-Trial Motions
|Document filed by USA. (Pomerantz, Lara) (Entered: 01/28/2021)</td></tr><tr><td>02/01/2021</td><td>129</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAs Maurene Comey, Alison Moe, and Lara Pomerantz dated February 1, 2021 re:
MDC Laptop Access Document filed by USA. (Comey, Maurene) (Entered:
02/01/2021)</td></tr><tr><td>02/01/2021</td><td>130</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C.
Sternheim dated 02/02/2021 re: Opposition to MDC letter (Sternheim, Bobbi)
(Entered: 02/01/2021)</td></tr><tr><td>02/02/2021</td><td>131</td><td>MEMO ENDORSEMENT as to Ghislaine Maxwell on Letter addressed to Judge
Alison J. Nathan from Sophia Papapetru (Staff Attorney, MDC Brooklyn, Federal
Bureau of Prisons) dated January 25, 2021. ENDORSEMENT: Having considered the
request submitted by the Bureau of Prisons ("BOP") that the Court vacate its January
15, 2021 Order, Dkt. No. 117, as well as the Government's and the Defendant's
responses, Dkt. Nos. 129, 130, the Court hereby DENIES the BOP's request to vacate
the Order. SO ORDERED. (Signed by Judge Alison J. Nathan on 2/2/2021)(bw)
(Entered: 02/02/2021)</td></tr><tr><td>02/04/2021</td><td>132</td><td>ORDER as to Ghislaine Maxwell: The Defendant is hereby ORDERED to docket the
redacted documents and corresponding exhibits by no later than February 5, 2021.
With respect to Motion 3, the Defendant is ORDERED to docket the version that
includes the Government's proposed redactions in addition to her own. SO
ORDERED. (Signed by Judge Alison J. Nathan on 2/4/2021)(See ORDER as set forth)
(Inl) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>133</td><td>MOTION to Suppress Under the Due Process Clause All Evidence Obtained from the
Governments Subpoena to REDACTED and to Dismiss Counts Five and Six.
Document filed by Ghislaine Maxwell. (Pagliuca, Jeffrey) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>134</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 133 MOTION to Suppress
Under the Due Process Clause All Evidence Obtained from the Governments
Subpoena to REDACTED and to Dismiss Counts Five and Six.. (Attachments: # 1
Exhibit A, #2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, #1
Exhibit G, #8 Exhibit H, #2 Exhibit I)(Pagliuca, Jeffrey) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>135</td><td>MOTION to Dismiss Counts Five and Six of the Superseding Indictment Because the
Alleged Misstatements are Not Perjurious as a Matter of Law. Document filed by
| Ghislaine Maxwell. (Pagliuca, Jeffrey) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>136</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 135 MOTION to Dismiss
Counts Five and Six of the Superseding Indictment Because the Alleged Misstatements
are Not Perjurious as a Matter of Law.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, #
3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H,
#2 Exhibit I, # 10 Exhibit J, # 11 Exhibit K)(Pagliuca, Jeffrey) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>137</td><td>MOTION to Dismiss Counts One Through Six of the Superseding Indictment for
Pre-Indictment Delay. Document filed by Ghislaine Maxwell. (Pagliuca, Jeffrey)
(Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>138</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 137 MOTION to Dismiss
Counts One Through Six of the Superseding Indictment for Pre-Indictment Delay..
(Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Pagliuca,
Jeffrey) (Entered: 02/04/2021)</td></tr></table>

# Case 21-58, Document 23, 03/29/2021, 3065988, Page21 of 24

<table><tr><th>02/04/2021</th><th>139</th><th>MOTION to Suppress Under the Fourth Amendment, Martindell, and the Fifth
Amendment All Evidence Obtained from the Governments Subpoena to REDACTED
and to Dismiss Counts Five And Six. Document filed by Ghislaine Maxwell. (Pagliuca,
Jeffrey) (Entered: 02/04/2021)</th></tr><tr><td>02/04/2021</td><td>140</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 139 MOTION to Suppress
Under the Fourth Amendment, Martindell, and the Fifth Amendment All Evidence
Obtained from the Governments Subpoena to REDACTED and to Dismiss Counts Five
And Six.. (Pagliuca, Jeffrey) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>141</td><td>MOTION to Dismiss the Superseding Indictment for Breach of Non-Prosecution
Agreement. Document filed by Ghislaine Maxwell. (Cohen, Mark) (Entered:
02/04/2021)</td></tr><tr><td>02/04/2021</td><td>142</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 141 MOTION to Dismiss the
Superseding Indictment for Breach of Non-Prosecution Agreement.. (Attachments: #
1 Exhibit A, #2 Exhibit B, # 3 Exhibit C (Sealed), # 4 Exhibit D (Sealed), # 5 Exhibit
E (Sealed), #6 Exhibit F (Sealed), # 7 Exhibit G (Sealed), #8 Exhibit H
(Sealed))(Cohen, Mark) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>143</td><td>MOTION to Dismiss Counts One Through Four of the Superseding Indictment as
Time-Barred. Document filed by Ghislaine Maxwell. (Cohen, Mark) (Entered:
02/04/2021)</td></tr><tr><td>02/04/2021</td><td>144</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 143 MOTION to Dismiss
Counts One Through Four of the Superseding Indictment as Time-Barred.. (Cohen,
Mark) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>145</td><td>MOTION to Strike Surplusage from Superseding Indictment. Document filed by
Ghislaine Maxwell. (Cohen, Mark) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>146</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 145 MOTION to Strike
Surplusage from Superseding Indictment.. (Cohen, Mark) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>147</td><td>MOTION for Bill of Particulars and Pretrial Disclosures. Document filed by
Ghislaine Maxwell. (Cohen, Mark) (Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>148</td><td>MEMORANDUM in Support by Ghislaine Maxwell re 147 MOTION for Bill of
Particulars and Pretrial Disclosures.. (Attachments: # 1 Exhibit A, # 2 Exhibit B
(Sealed), #3 Exhibit C (Sealed), # 4 Exhibit D (Sealed), # 5 Exhibit E)(Cohen, Mark)
(Entered: 02/04/2021)</td></tr><tr><td>02/04/2021</td><td>149</td><td>AFFIDAVIT of Bobbi C. Sternheim in Support as to Ghislaine Maxwell re 147
MOTION for Bill of Particulars and Pretrial Disclosures.. (Cohen, Mark) (Entered:
02/04/2021)</td></tr><tr><td>02/05/2021</td><td>150</td><td>SEALED DOCUMENT placed in vault. (jri) (Entered: 02/05/2021)</td></tr><tr><td>02/05/2021</td><td>151</td><td>SEALED DOCUMENT placed in vault. (jri) (Entered: 02/05/2021)</td></tr><tr><td>02/05/2021</td><td>152</td><td>SEALED DOCUMENT placed in vault. (jri) (Entered: 02/05/2021)</td></tr><tr><td>02/05/2021</td><td>153</td><td>SEALED DOCUMENT placed in vault. (jri) (Entered: 02/05/2021)</td></tr><tr><td>02/05/2021</td><td>154</td><td>SEALED DOCUMENT placed in vault. (jri) (Entered: 02/05/2021)</td></tr><tr><td>02/05/2021</td><td>155</td><td>SEALED DOCUMENT placed in vault. (jri) (Entered: 02/05/2021)</td></tr><tr><td>02/05/2021</td><td>156</td><td>SEALED DOCUMENT placed in vault. (jri) (Entered: 02/05/2021)</td></tr><tr><td>02/05/2021</td><td>157</td><td>SEALED DOCUMENT placed in vault. (jri) (Entered: 02/05/2021)</td></tr><tr><td>02/05/2021</td><td>158</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, and Lara Pomerantz dated February 5, 2021 re:
MDC Conditions Update Document filed by USA. (Comey, Maurene) (Entered:
02/05/2021)</td></tr><tr><td>02/16/2021</td><td>159</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C.
Sternheim dated 02/16/2021 re: Conditions of Pretrial Confinement (Sternheim,
Bobbi) (Entered: 02/16/2021)</td></tr></table>

# Case 21-58, Document 23, 03/29/2021, 3065988, Page22 of 24

<table><tr><th>02/23/2021</th><th>160</th><th>THIRD MOTION for Bond. Document filed by Ghislaine Maxwell. (Sternheim,
Bobbi) (Entered: 02/23/2021)</th></tr><tr><td>02/24/2021</td><td>161</td><td>ORDER as to Ghislaine Maxwell: On February 23, 2021, Defendant Ghislaine
Maxwell filed a third motion for release on bail. Dkt. No. 160. The Government's
response is due March 9, 2021, and the Defendants reply is due March 16, 2021. SO
ORDERED. (Responses due by 3/9/2021. Replies due by 3/16/2021.) (Signed by
Judge Alison J. Nathan on 2/24/2021) (Inl) (Entered: 02/24/2021)</td></tr><tr><td>02/26/2021</td><td>162</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated
February 26, 2021 re: Cover Letter for Government Opposition to Defense Pretrial
Motions Document filed by USA. (Comey, Maurene) (Entered: 02/26/2021)</td></tr><tr><td>03/01/2021</td><td>163</td><td>LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated March 1, 2021 re: Extension of Time to File Reply to Government Opposition to
Defense Pretrial Motions. Document filed by Ghislaine Maxwell. (Everdell, Christian)
(Entered: 03/01/2021)</td></tr><tr><td>03/01/2021</td><td>164</td><td>MEMO ENDORSEMENT 163 LETTER MOTION To request a 10-day extension of
time until Monday, March 15, 2021 to file our reply re: 163 LETTER MOTION
addressed to Judge Alison J. Nathan from Christian R. Everdell dated March 1, 2021
re: Extension of Time to File Briefing Schedule...ENDORSEMENT... The Defendant's
request is GRANTED. Her reply to the Government's Omnibus Memorandum in
Opposition to the Defendants Pretrial Motions is now due on March 15, 2021. SO
ORDERED. (Signed by Judge Alison J. Nathan on 3/1/21) (jw) (Entered: 03/01/2021)</td></tr><tr><td>03/01/2021</td><td></td><td>Set/Reset Deadlines/Hearings as to Ghislaine Maxwell: Defendant Replies due by
3/15/2021 (jw) (Entered: 03/01/2021)</td></tr><tr><td>03/09/2021</td><td>165</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAs Maurene Comey, Alison Moe, and Lara Pomerantz dated March 9, 2021 re:
Opposition to Third Bail Motion Document filed by USA. (Attachments: # 1 Exhibit
A)(Pomerantz, Lara) (Entered: 03/09/2021)</td></tr><tr><td>03/15/2021</td><td>166</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R.
Everdell dated March 15, 2021 re: Pretrial Motion Replies (Everdell, Christian)
(Entered: 03/15/2021)</td></tr><tr><td>03/16/2021</td><td>167</td><td>LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C.
Sternheim dated 03/16/2021 re: Letter regarding Reply to Bail Motion (Sternheim,
Bobbi) (Entered: 03/16/2021)</td></tr><tr><td>03/18/2021</td><td>168</td><td>ORDER as to Ghislaine Maxwell. On February 26, 2021, the Government filed its
omnibus memorandum of law opposing Defendants' twelve pretrial motions. It filed
the brief, along with the corresponding exhibits, under temporary seal pending the
Court's resolution of its request to redact sensitive or confidential information. See
Dkt. No. 162. On March 9, 2021, the Defendant objected to certain of the redactions
that the Government had proposed, and she proposed additional redactions. Having
considered the parties' respective positions, the Court will grant the Government's
requests for redactions and sealing, as well as the Defendant's additional redaction
requests, with the exceptions discussed below. Finally, the Court denies the
Governments request to file Exhibit 11 entirely under seal. While portions of that
transcript have been redacted, other portions are part of the public record. See Giuffre
v. Maxwell, Case No. 15-cv-7433, Dkt. No. 1212-1. In light of this, the Court sees
no basis to file the transcript entirely under seal rather than by redacting the relevant
portions. In light of the above, the Government is hereby ORDERED to either docket
on ECF their brief and the corresponding exhibits, consistent with this Order, or to file
a letter with the Court justifying more tailored redaction and sealing requests regarding
pages 1128 and 187188 and Exhibits 8 and 9 by no later than March 22, 2021. The
parties are further ORDERED to meet, confer, and jointly propose redactions to the
Defendant's cover letter objecting to the Government's proposed redactions by March
22, 2021. Finally, the parties are ORDERED to meet, confer, and propose redactions
to Exhibit 11 of the Government's submission by March 22, 2021 (Signed by Judge
Alison J. Nathan on 3/18/21)(jw) (Entered: 03/18/2021)</td></tr></table>

# Case 21-58, Document 23, 03/29/2021, 3065988, Page23 of 24

<table><tr><th>03/22/2021</th><th>169</th><th>ORDER as to Ghislaine Maxwell: Defendant Ghislaine Maxwell's third motion for
release on bail, Dkt. No. 160, is DENIED. The parties are ORDERED to meet and
confer and propose and justify any redactions to the Defendant's reply brief by March
24, 2021. If they conclude that redactions are unnecessary, the Defendant is
ORDERED to docket the unredacted version of the brief by March 24, 2021. (Signed
by Judge Alison J. Nathan on 3/22/2021) (See ORDER set forth) (ap) Modified on
| 3/23/2021 (ap). (Entered: 03/22/2021)</th></tr><tr><td>03/22/2021</td><td>170</td><td>LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAS Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated
March 22, 2021 re: Redactions to Government Opposition to Defense Pretrial Motions
Document filed by USA. (Pomerantz, Lara) (Entered: 03/22/2021)</td></tr><tr><td>03/23/2021</td><td>171</td><td>REPLY MEMORANDUM OF LAW in Support as to Ghislaine Maxwell re: 160
THIRD MOTION for Bond. . (Sternheim, Bobbi) (Entered: 03/23/2021)</td></tr><tr><td>03/24/2021</td><td>172</td><td>ORDER as to Ghislaine Maxwell. On March 5, 2021, Defendant Ghislaine Maxwell
submitted to the Court an application for an order authorizing a subpoena pursuant to
Rule 17(c)(3) of the Federal Rules of Criminal Procedure. The proposed subpoena was
directed at a law firm that represents alleged victims of the Defendant. As is standard
for Rule 17(c) subpoenas, the application was made ex parte and under seal on the
ground that it reveals defense strategy.... [*** See this Order ***]... Rule 17(c)(3)
provides that "[a]fter [an indictment] is filed, a subpoena requiring the production of
personal or confidential information about a victim may be served on a third party only
by court order," but "before entering the order and unless there are exceptional
circumstances, the court must require giving notice to the victim so that the victim can
move to quash or modify the subpoena or otherwise object." Fed. R. Crim. P. 17(c)(3).
Consistent with the Rule, on March 12, 2021, in a sealed ex parte Order, the Court
required defense counsel to provide notice to alleged victims whose personal or
confidential information may be disclosed by the proposed subpoena. The Court also
gave the alleged victims an opportunity to object to or request modifications of the
subpoena as required by Rule 17(c)(3). On March 19, 2021, the Court received a letter
from the law firm indicating that it can provide notice to alleged victims whose
personal or confidential information may be elicited by the subpoena. The law firm
shall provide notice to any such alleged victims it represents. In that letter, the law firm
also interposed substantial objections on behalf of the law firm and the alleged victims
it represents. Those objections are functionally the equivalent of a motion to quash,
even though the subpoena has not yet issued. So that the Court can receive adversarial
briefing on the proposed subpoena comparable to a motion to quash, the law firm shall
enter an appearance and file its objections on the public docket. See United States v.
Ray, No. 20-CR-110 (LJL), 2020 WL 6939677, at *10 (S.D.N.Y. Nov. 25, 2020)
("[I]f the Court determines that the subpoena calls for personal or confidential
information about a victim, it requires the requesting party have given notice to the
victim before it permits the service of the subpoena. If the victim objects, the Court
will then determine whether to modify or quash the subpoena, including on grounds
that Nixon was not satisfied."). In advance of noticing an appearance and filing, the
law firm shall meet and confer with defense counsel to see if any issues can be
narrowed before formal briefing. Moreover, prior to filing, the law firm shall confer
with defense counsel as to any proposed, necessary, and tailored redactions to the
objections. The law firm's objections with any proposed redactions shall be filed on or
before March 26, 2021. Any redactions must be justified consistent with Lugosch v.
Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Within one week of the filing
of objections, defense counsel may respond to the subpoena objections. The law firm
may reply within three days of the Defendant's response. (See Citation 1 on this Order).
Counsel shall confer regarding any proposed redactions for all briefing. SO
ORDERED. (Signed by Judge Alison J. Nathan on 3/24/2021)(bw) (Entered:
03/24/2021)</td></tr><tr><td>03/24/2021</td><td>173</td><td>NOTICE OF APPEAL by Ghislaine Maxwell from 169 Order, Terminate Motions.
(tp) (Entered: 03/24/2021)</td></tr><tr><td>03/24/2021</td><td></td><td>Appeal Remark as to Ghislaine Maxwell re: 173 Notice of Appeal. $505.00 Appeal
Fee Due. (tp) (Entered: 03/24/2021)</td></tr><tr><td>03/24/2021</td><td></td><td>Transmission of Notice of Appeal and Certified Copy of Docket Sheet as to Ghislaine
Maxwell to US Court of Appeals re: 173 Notice of Appeal. (tp) (Entered: 03/24/2021)</td></tr></table>

# Case 21-58, Document 23, 03/29/2021, 3065988, Page24 of 24

<table><tr><th>03/24/2021</th><th></th><th>Appeal Record Sent to USCA (Electronic File). Certified Indexed record on Appeal
Electronic Files as to Ghislaine Maxwell re: 173 Notice of Appeal were transmitted to
the U.S. Court of Appeals. (tp) (Entered: 03/24/2021)</th></tr><tr><td>03/24/2021</td><td>174</td><td>SEALED DOCUMENT placed in vault. (dn) (Entered: 03/24/2021)</td></tr><tr><td>03/24/2021</td><td>175</td><td>SEALED DOCUMENT placed in vault. (dn) (Entered: 03/24/2021)</td></tr><tr><td>03/24/2021</td><td>176</td><td>SEALED DOCUMENT placed in vault. (dn) (Entered: 03/24/2021)</td></tr></table>

# Case 21-58, Document 24, 03/30/2021, 3066424, Page1 of 1

NOTICE OF APPEARANCE FOR SUBSTITUTE, ADDITIONAL, OR AMICUS COUNSEL

Short Title: United States v. Maxwell
Docket No.: 21-770

Substitute, Additional, or Amicus Counsel's Contact Information is as follows:

Name: Maureen Comey
Firm: United States Attorney's Office for the Southern District of New York
Address: One St. Andrew's Plaza
Telephone: (212) 637-2324
Fax: (212) 637-2387
E-mail: maureen.comey@usdoj.gov

Appearance for: United States of America/Appellee (party/designation)

Select One:
[ ] Substitute counsel (replacing lead counsel: <empty>)
(name/firm)
[ ] Substitute counsel (replacing other counsel: <empty>)
(name/firm)
[x] Additional counsel (co-counsel with: Won S. Shin/U.S. Attorney's Office for the Southern District of New York)
(name/firm)
[ ] Amicus (in support of : <empty>)
(party/designation)

## CERTIFICATION

I certify that:
[x] I am admitted to practice in this Court and, if required by Interim Local Rule 46.1(a)(2), have renewed my admission on November 5, 2020 OR 
[ ] I applied for admission on <empty>.
Signature of Counsel: /s/Maureen Comey
Type or Print Name: Maureen Comey

# Case 21-58, Document 25, 03/30/2021, 3066859, Page1 of 1

NOTICE OF APPEARANCE FOR SUBSTITUTE, ADDITIONAL, OR AMICUS COUNSEL

Short Title: United States v. Maxwell
Docket No.: 21-770

Substitute, Additional, or Amicus Counsel's Contact Information is as follows:

Name: Lara Pomerantz
Firm: United States Attorney's Office for the Southern District of New York
Address: One St. Andrew's Plaza
Telephone: (212) 637-2343
Fax: <empty>
E-mail: lara.pomerantz@usdoj.gov

Appearance for: United States of America/Appellee (party/designation)

Select One:
[ ] Substitute counsel (replacing lead counsel: <empty>)
(name/firm)

[ ] Substitute counsel (replacing other counsel: <empty>)
(name/firm)

[x] Additional counsel (co-counsel with: Won S. Shin/U.S. Attorney's Office for the Southern District of New York)
(name/firm)

[ ] Amicus (in support of : <empty>)
(party/designation)

## CERTIFICATION

I certify that:
[x] I am admitted to practice in this Court and, if required by Interim Local Rule 46.1(a)(2), have renewed my admission on December 3, 2020 OR 
[ ] I applied for admission on <empty>.
Signature of Counsel: /s/ Lara Pomerantz
Type or Print Name: Lara Pomerantz

Case 21-58, Document 30, 04/01/2021, 3068130, Page1 of 2

# United States Court of Appeals for the Second Circuit Thurgood Marshall U.S. Courthouse 40 Foley Square New York, NY 10007

DEBRA ANN LIVINGSTON
CHIEF JUDGE

Date: April 01, 2021 Docket #: 21-770 Short Title: United States of America v. Maxwell

CATHERINE O'HAGAN WOLFE
CLERK OF COURT
DC Docket #: 1:20-cr-330-1
DC Court: SDNY (NEW YORK
CITY DC Docket #: 1:20-cr-330-
1
DC Court: SDNY (NEW YORK
CITY)
DC Judge: Nathan

# NOTICE OF DEFECTIVE FILING

On March 30, 2021 the Notice of Appearance as Substitute Counsel, on behalf of the Appellant Ghislaine Maxwell was submitted in the above referenced case. The document does not comply with the FRAP or the Court's Local Rules for the following reason:

# NOTICE OF DEFECTIVE FILING (cont.)

- Failure to submit acknowledgment and notice of appearance (Local Rule 12.3)

- Failure to file the Record on Appeal (FRAP 10, FRAP 11)

- Missing motion information statement (T-1080 - Local Rule 27.1)

- Missing supporting papers for motion (e.g, affidavit/affirmation/declaration) (FRAP 27) Insufficient number of copies (Local Rules: 21.1, 27.1, 30.1, 31.1)

- Improper proof of service (FRAP 25)

	- Missing proof of service

	- Served to an incorrect address

	- Incomplete service (Anders v. California 386 U.S. 738 (1967))

- Failure to submit document in digital format (Local Rule 25.1)

- Not Text-Searchable (Local Rule 25.1, Local Rules 25.2), click here

- for instructions on how to make PDFs text searchable

- Failure to file appendix on CD-ROM (Local Rule 25.1, Local Rules 25.2)

- Failure to file special appendix (Local Rule 32.1)

- Defective cover (FRAP 32)

	- Incorrect caption (FRAP 32)

	- Wrong color cover (FRAP 32)

	- Docket number font too small (Local Rule 32.1)

- Incorrect pagination, click here for instructions on how to paginate PDFs (Local Rule 32.1)

- Incorrect font (FRAP 32)

# NOTICE OF DEFECTIVE FILING (cont.)

Case 21-58, Document 30, 04/01/2021, 3068130, Page2 of 2

Oversized filing (FRAP 27 (motion), FRAP 32 (brief)) Missing Amicus Curiae filing or motion (Local Rule 29.1) Untimely filing Incorrect Filing Event

# ✗ Other: If Christian R. Everdell wishes to be substituted, counsel must file a motion to be relieved, see Local Rule 4.1(d)(2).

Please cure the defect and resubmit the document, with the required copies if necessary, no later than April 05, 2021. The resubmitted documents, if compliant with FRAP and the Local Rules, will be deemed timely filed.

Failure to cure the defect by the date set forth above will result in the document being stricken. An appellant's failure to cure a defective filing may result in the dismissal of the appeal.

Inquiries regarding this case may be directed to 212-857-8577.

Case 21-58, Document 32, 04/01/2021, 3068158, Page1 of 2

# United States Court of Appeals for the Second Circuit Thurgood Marshall U.S. Courthouse 40 Foley Square New York, NY 10007

DEBRA ANN LIVINGSTON
CHIEF JUDGE

Date: April 01, 2021 Docket #: 21-58 Short Title: United States of America v. Maxwell

CATHERINE O'HAGAN WOLFE
CLERK OF COURT
DC Docket #: 1:20-cr-330-1
DC Court: SDNY (NEW YORK
CITY DC Docket #: 1:20-cr-330-
1
DC Court: SDNY (NEW YORK
CITY)
DC Judge: Nathan

# NOTICE OF DEFECTIVE FILING

On April 01, 2021 the Notice of Appearance as Additional Counsel, on behalf of the Appellant Ghislaine Maxwell was submitted in the above referenced case. The document does not comply with the FRAP or the Court's Local Rules for the following reason:

# NOTICE OF DEFECTIVE FILING (cont.)

	- Failure to submit acknowledgment and notice of appearance (Local Rule 12.3)

	- Failure to file the Record on Appeal (FRAP 10, FRAP 11)

	- Missing motion information statement (T-1080 - Local Rule 27.1)

	- Missing supporting papers for motion (e.g, affidavit/affirmation/declaration) (FRAP 27) Insufficient number of copies (Local Rules: 21.1, 27.1, 30.1, 31.1)

	- Improper proof of service (FRAP 25)

		- Missing proof of service

		- Served to an incorrect address

		- Incomplete service (Anders v. California 386 U.S. 738 (1967))

	- Failure to submit document in digital format (Local Rule 25.1)

- X Not Text-Searchable (Local Rule 25.1, Local Rules 25.2), click here

	- for instructions on how to make PDFs text searchable

	- Failure to file appendix on CD-ROM (Local Rule 25.1, Local Rules 25.2)

	- Failure to file special appendix (Local Rule 32.1)

	- Defective cover (FRAP 32)

		- Incorrect caption (FRAP 32)

		- Wrong color cover (FRAP 32)

		- Docket number font too small (Local Rule 32.1)

	- Incorrect pagination, click here for instructions on how to paginate PDFs (Local Rule 32.1)

	- Incorrect font (FRAP 32)

# NOTICE OF DEFECTIVE FILING (cont.)

Case 21-58, Document 32, 04/01/2021, 3068158, Page2 of 2

Oversized filing (FRAP 27 (motion), FRAP 32 (brief))
Missing Amicus Curiae filing or motion (Local Rule 29.1)
Untimely filing
Incorrect Filing Event
Other:

Please cure the defect and resubmit the document, with the required copies if necessary, no later than April 05, 2021. The resubmitted documents, if compliant with FRAP and the Local Rules, will be deemed timely filed.

Failure to cure the defect by the date set forth above will result in the document being stricken. An appellant's failure to cure a defective filing may result in the dismissal of the appeal.

Inquiries regarding this case may be directed to 212-857-8577.

# NOTICE OF DEFECTIVE FILING (cont.)

Case 21-58, Document 33, 04/01/2021, 3068185, Page1 of 1 NOTICE OF APPEARANCE FOR SUBSTITUTE, ADDITIONAL, OR AMICUS COUNSEL

Short Title: United States of America v. Maxwell
Docket No.: 21-770/21-58

Substitute, Additional, or Amicus Counsel's Contact Information is as follows:

Name: David Oscar Markus
Firm: Markus/Moss PLLC
Address: 40 NW Third Street, PH 1, Miami, Florida 33128
Telephone: (305)379-6667
Fax: (305)379-6668
E-mail: dmarkus@markuslaw.com
Appearance for: Ghislaine Maxwell (party/designation)

Select One:
[ ] Substitute counsel (replacing lead counsel:<empty>)
(name/firm)
[ ] Substitute counsel (replacing other counsel:<empty>)
(name/firm)
[x] Additional counsel (co-counsel with: Christian R. Everdell/Cohen & Gresser LLP)
(name/firm)
[ ] Amicus (in support of:<empty>)
(party/designation)

## CERTIFICATION

I certify that:
[x] I am admitted to practice in this Court and, if required by Interim Local Rule 46.1(a)(2), have renewed my admission on <empty> OR
[ ] I applied for admission on <empty>

Signature of Counsel: <signature>
Type or Print Name: David Oscar Markus

Case 21-58, Document 37, 04/01/2021, 3068308, Page1 of 2

# United States Court of Appeals for the Second Circuit Thurgood Marshall U.S. Courthouse 40 Foley Square New York, NY 10007

DEBRA ANN LIVINGSTON
CHIEF JUDGE

Date: April 01, 2021 Docket #: 21-58 Short Title: United States of America v. Maxwell

CATHERINE O'HAGAN WOLFE
CLERK OF COURT
DC Docket #: 1:20-cr-330-1
DC Court: SDNY (NEW YORK
CITY DC Docket #: 1:20-cr-330-
1
DC Court: SDNY (NEW YORK
CITY)
DC Judge: Nathan

# NOTICE OF DEFECTIVE FILING

On April 01, 2021 the motion for bail, on behalf of the Appellant Ghislaine Maxwell, was submitted in the above referenced case. The document does not comply with the FRAP or the Court's Local Rules for the following reason:

# NOTICE OF DEFECTIVE FILING (cont.)

	- Failure to submit acknowledgment and notice of appearance (Local Rule 12.3)

	- Failure to file the Record on Appeal (FRAP 10, FRAP 11)

	- Missing motion information statement (T-1080 - Local Rule 27.1)

	- Missing supporting papers for motion (e.g, affidavit/affirmation/declaration) (FRAP 27) Insufficient number of copies (Local Rules: 21.1, 27.1, 30.1, 31.1)

	- Improper proof of service (FRAP 25)

		- Missing proof of service

		- Served to an incorrect address

		- Incomplete service (Anders v. California 386 U.S. 738 (1967))

	- Failure to submit document in digital format (Local Rule 25.1)

- X Not Text-Searchable (Local Rule 25.1, Local Rules 25.2), click here

	- for instructions on how to make PDFs text searchable

	- Failure to file appendix on CD-ROM (Local Rule 25.1, Local Rules 25.2)

	- Failure to file special appendix (Local Rule 32.1)

	- Defective cover (FRAP 32)

		- Incorrect caption (FRAP 32)

		- Wrong color cover (FRAP 32)

		- Docket number font too small (Local Rule 32.1)

	- Incorrect pagination, click here for instructions on how to paginate PDFs (Local Rule 32.1)

	- Incorrect font (FRAP 32)

# NOTICE OF DEFECTIVE FILING (cont.)

Case 21-58, Document 37, 04/01/2021, 3068308, Page2 of 2

Oversized filing (FRAP 27 (motion), FRAP 32 (brief))
Missing Amicus Curiae filing or motion (Local Rule 29.1)
Untimely filing
Incorrect Filing Event

# X Other: ALL PAGES MUST BE TEXT-SEARCHABLE, INCLUDING T-1080
AND EXHIBITS.

Please cure the defect and resubmit the document, with the required copies if necessary, no later than April 05, 2021. The resubmitted documents, if compliant with FRAP and the Local Rules, will be deemed timely filed.

Failure to cure the defect by the date set forth above will result in the document being stricken. An appellant's failure to cure a defective filing may result in the dismissal of the appeal.

Inquiries regarding this case may be directed to 212-857-8577.
documents/doj-371e7e11e006ca74.pdf
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