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Case 1:17-mc-00025-RWS Document 6 Filed 06/29/16 Page 1 of 3
Jeffrey S. Pagliuca (pro hac vice)
HADDON, MORGAN AND FOREMAN, P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303.831.7364
Fax: 303.832.2628
jpagliuca@hmflaw.com
Denise D. Riley (# 160245)
Riley Law PLLC
2710 Del Prado Blvd. S., Unit 2-246,
Cape Coral, FL 33904
Phone: 303.907.0075
denise@rileylawpl.com
Attorneys for Ghislaine Maxwell
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
In re: SUBPOENA TO BRADLEY J.
EDWARDS
MOTION TO FILE CERTAIN EXHIBITS
Underlying case: UNDER SEAL
VIRGINIA L. GIUFFRE, Plaintiff
Case Number 0:16-mc-61262-JEM
v.
GHISLAINE MAXWELL, Defendant
No. 15-cv-07433-RWS (S.D.N.Y.)
Defendant Ghislaine Maxwell pursuant to Rule 5.4 (b) of the Local Rules of the U.S.
District Court for the Southern District of Florida, requests permission to file exhibits A, G, H, I,
and N, attached to the Declaration of Jeffrey S. Pagliuca In Support of Defendant Ghislaine
Maxwell’s Response In Opposition of Motion of Bradley J. Edwards Motion to Quash Subpoena
or, in the Alternative, for a Protective Order, under seal for the following reason:
Case 1:17-mc-00025-RWS Document 6 Filed 06/29/16 Page 2 of 3
1. Exhibits A, G, H, I, and N have been designated CONFIDENTIAL pursuant to a
protective order issued by the U.S. District Court in the Southern District of New
York in the underlying matter, Giuffre v. Maxwell, 15-cv-07433-RWS.
2. Under the terms of the protective order documents designated confidential may not be
shared publicly.
3. Ms. Maxwell requests that the exhibits be permanently sealed.
Dated June 29, 2016
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