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lings regarding those matters, including the discovery materials referenced in the Defense Letter, remain sealed? As the U.S. Attorney's Office for the Southern District of New York has stated publicly, the investigation into the conduct of the defendant in this case and other possible co-conspirators of Jeffrey Epstein remains
Page: EFTA00017807 →g the relative lack of specific guidance in the context of an application to modify protective orders in criminal cases), see also United States v. Morales, 807 F.3d 717, 721 (5th Cir. 2015) ("[m]otions to modify protective orders in criminal cases appear to be infrequent"), decisions that do exist have
Page: EFTA00017808 →LC), Apr. 13, 2017) 24 Martindell v. Intl Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979) 18, 21 McNabb v. United States, 318 U.S. 332 (1943) 20 Morales v. Portuondo, 165 F. Supp. 2d 601 (S.D.N.Y. 2001) 24 Rea v. United States, 350 U.S. 214 (1956) 20 United States v. Bout, 731 F.3d 233 (2d Cir. 20
Page: EFTA00028931 →on first began. None of these statements by AUSA to Judge McMahon were true. As described above, attorneys pressed the U.S. Attorney's Office for the Southern District of New York to investigate and prosecute Epstein and Maxwell. Ex. J. Then, two months after the meeting with AUSA attorneys told Judge Sweet—who was presiding
Page: EFTA00028937 →C), Apr. 13, 2017) 24 Martindell v. Intl Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979) 18, 21 McNabb v. United States, 318 U.S. 332 (1943) 20 Morales v. Portuondo, 165 F. Supp. 2d 601 2001) 24 Rea v. United States, 350 U.S. 214 (1956) 20 United States v. Bout, 731 F.3d 233 (2d Cir. 2013) 23
Page: EFTA00029102 →on first began. None of these statements by AUSA to Judge McMahon were true. As described above, attorneys pressed the U.S. Attorney's Office for the Southern District of New York to investigate and prosecute Epstein and Maxwell. Ex. J. Then, two months after the meeting with AUSA attorneys told Judge Sweet—who was presiding
Page: EFTA00029108 →the FBI submitted a revised declaration from Maureen Comey, an Assistant United States Attorney ("AUSA") in the United States Attorney's Office for the Southern District of New York. (Third Comey Decl. (Dkt. No. 59)1 1), and a revised declaration from Michael G. Seidel, the Section Chief of the Record/Information Dissemination
Page: EFTA00038653 →GG Document 64 Filed 06/25/24 Page 7 of 20 "The same standard[s] appl[y] where, as here, the parties file[] cross-motions for summary judgment...." Morales v. Ouintel Entm't. Inc., 249 F.3d 115, 121 (2d Cir. 2001). "[W]hen both parties move for summary judgment, asserting the absence of any genuine issu
Page: EFTA00038658 →Entities connected to both Morales and District Court for the Southern District of New York

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
Audrey Strauss
PERSON
Marc Rich
PERSON
Donald Trump
PERSONU.S. Attorney's Office
ORGANIZATION
Geoffrey S. Berman
PERSON
Alison J. Nathan
PERSONJane Doe
PERSONFBI
ORGANIZATIONSecond Circuit
ORGANIZATION
New Hampshire
LOCATION
Julie K. Brown
PERSON
Virginia Giuffre
PERSON
Bill Clinton
PERSON
George W. Bush
PERSON
Michael Cohen
PERSON