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York United States Courthouse New York, New York 10007 Re: In re Application to Unseal Civil Discovery Materials, USAO No. 2018R01618 Dear Judge Sweet: The Government writes respectfully in connection with its sealed application and proposed order pursuant to the All Writs Act, Title 28, United St
proceeding such as in Subpoena Duces Tecum-relied upon the Protective Order to indefinitely keep the relevant materials hidden. In this case, where the Protective Order is limited by its terms to only the pretrial stages of the civil litigation, no confidential business information appears to be at issue, and counse
S-cv-07433 United States District Court For the Southern District of New York March 17, 2016 Protective Order by United States District Court Judge Sweet The undersigned acknowledges that he has read the above-referenced Protective Order, a copy of which is attached, and agrees to be bound by the prov
that case.' Under the terms of the Protective Order, "Confidential" documents "shall not be disclosed or used for any purpose except the A copy of the Protective Order is attached hereto as Exhibit A. Out of respect for the provisions of the Protective Order, we are submitting this letter under seal. EFTA00793037
York United States Courthouse New York, New York 10007 Re: In re Application to Unseal Civil Discovery Materials, USAO No. 2018R01618 Dear Judge Sweet: The Government writes respectfully in connection with its sealed application and proposed order pursuant to the All Writs Act, Title 28, United St
proceeding such as in Subpoena Duces Tecwn—relied upon the Protective Order to indefinitely keep the relevant materials hidden. In this case, where the Protective Order is limited by its terms to only the pretrial stages of the civil litigation, no confidential business information appears to be at issue, and counse
York United States Courthouse New York, New York 10007 Re: In re Application to Unseal Civil Discovery Materials, USAO No. 2018R01618 Dear Judge Sweet: The Government writes respectfully in connection with its sealed application and proposed order pursuant to the All Writs Act, Title 28, United St
proceeding such as in Subpoena Duces Tecwn—relied upon the Protective Order to indefinitely keep the relevant materials hidden. In this case, where the Protective Order is limited by its terms to only the pretrial stages of the civil litigation, no confidential business information appears to be at issue, and counse
fendants' request, and issued an Order under seal, directing (a) Defendants to make their application for relief from the Protective Order to Judge Sweet and (b) file their Motion to Dismiss within seven (7) days after Judge Sweet's decision (the "July 17 Order"). Contrary to Mr. Edwards' contention,
ed for any deposition of Mr. Epstein. We respectfully submit that there is no reason to deviate from the July 17 Order. The motion for relief from the Protective Order has been submitted to Judge Sweet. Once Judge Sweet rules on the motion, Defendants will submit their Motion to Dismiss within seven (7) days. The
ents that were placed under seal and included in protective order. Holdings: The United States District Court for the Southern District of New York, Sweet, J., held that: m news media and journalist could intervene in action; 121 public did not have right of access, either under First Amendment or co
Page: EFTA00020541 →mmon law right of access, or of the more robust First Amendment right to access certain judicial documents. Id. at 119-20. It is a given accepted by the Protective Order that the trial and all trial documents are accessible and public absent special circumstances. *8 1121 II3IUnder the common law approach, once a do
Page: EFTA00020562 →Entities connected to both Sweet and the Protective Order

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSON
David Boies
PERSON
United States
LOCATION
Virginia Giuffre
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSON
Julie K. Brown
PERSONSigrid McCawley
PERSON
Prince Andrew
PERSONthe Southern District
LOCATION
Alexander Acosta
PERSON
Alan Dershowitz
PERSON
Kenneth Marra
PERSON
Department of Justice
ORGANIZATIONMartindell
PERSON
Southern District of New York
ORGANIZATIONSouthern District
LOCATION
Jay Lefkowitz
PERSON