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HISLAINE MAXWELL 2 II. THE OVERBROAD SEALING ORDER AND PRIOR ATTEMPTS TO UNSEAL 3 III. THE ORDER DENYING THE MOTIONS TO UNSEAL 6 ARGUMENT 6 I. MIAMI HERALD MEDIA HAS THE RIGHT TO INTERVENE AS A NEWS ORGANIZATION 7 II. THE PRESUMPTION OF OPENNESS UNDER THE COMMON LAW AND FIRST AMENDMENT APPLY TO THE
and unseal all of the documents in the above-captioned action that have been filed under seal or redacted. These judicial documents are germane to the Miami Herald's ongoing coverage of dozens of underage minors who were victims of Jeffrey Epstein, the South Florida financier who pleaded guilty in 2008 to solicit
2006) 15 Landmark Commcins, Inc. v. Virginia, 435 U.S. 829 (1978) 10 Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) passim Mitchell v. Fishbein, 227 F.R.D. 239 (S.D.N.Y. 2005) 15 Nebraska Press Ass'n v. Stuart, 427 U.S. 539 (1976) 10 Nixon v. Warner Corn:wins, Inc., 435 U.S
arris, Wyetha Fel U) Harrison, Linda Juv K) Hartwell, Kristina DOVE-TO) Harvey, Lauren DOVE-TD) Harvey, Lynn DOVE-Fell Head, Amanda CC L) Heald, Patricia CC L) Hearsurn, Debra Fel W) Herbits, Linda JlmmyRyce) Herman, Ron So Cnty) Hernandez, Janine CC E) Herat, Dana Collier CC 8) Hi
iano, Arleen So Cnty) Lyles, Jennifer K) Lyles, Richard CAC) Mack, Renelda Appeals) Macon, Carla INVEST) Mac Vane, Sandi JUVENILE) Marken, Michelle ;Info Res) Marshall, Deborah Fel U) Martin, Rachel Info Res) McCloskey, Melissa DoBeivEle r McFadden, Glade MccGCooyy,eJrn.T Desiree .polly CA
eazy trader Jeff Steed in Douglas Stumpfs Confessions of a Wall Street Shoeshine Boy. All of which makes Epstein, like, the most famous sex offender George Michael! Even if he's not registered, surely they'll be able to recognize him at the American Girl Place. Epstein Eyes Sex-Rap Relief [NYP] Jeffrey Epstein
r3ent officialsarho told him that pE stein was an individu portrinoe-usthrgr7et tit • it. nm' s ,Lb Rib I part of the negotiations, according to the Miami Hera , p ean provia- ed information" to the Florida federal prosecutors for a more lenient sentence and was supposedly an unnamed key witness for the Ne
sobel Redmond for the Liberal Party leadership or Mitch Williams for the deputy leadership?) On 19 Octob
ording to him, beta higher government ofReielsa o told Mm that Epstein was an in" o ce to e government . or the negotiations, according to the Mimi Herald, Epstein provided "unspecified in_ocitation" to the Florida federal prosecutors for a more lenient sentence and was supposedly an unnamed key witnes
ey" HAI-Pe-NE-0 NUT A NORMAL ReAcitc^.1 "Well I guess I'm not going to see my little India Rose again" - Suspected and reported abducted child of Michelle and Brett, Port Pirie - Reported to Federal Police, Melbourne Victoria, Head Quarters - Child is in the possession of Toni, New Zealand / Paul Gardn
a Does 3 and 4. to join the suit, Marra specifically said that may later give evidence when the case comes to courtP383 ep 5176_ tts) WitNe: ()CC Miami Harald, Harald, On February 21, 2019, in the case of Two Jane Does v. United States, Senior Judge of the U.S. District Court for the Southern District of
her head down towards the floor and rushed away quickly , did not say hello or acknowledge me in anyway. Michelle - Adelaide University - employee Michelle kept messaging Vincent day and night through personal messaging apps with her personal issues. Contacted Vincent once at 4am in the morning with her
Entities connected to both The Miami Herald and George Mitchell

Jeffrey Epstein
PERSON
Lesley Groff
PERSONLeon Black
PERSON
Marc Rich
PERSON
Richard Kahn
PERSON
Prince Andrew
PERSONDarren Indyke
PERSON
Woody Allen
PERSON
Stephen Hawking
PERSON
Ghislaine Maxwell
PERSON
Donald Trump
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
John F. Kennedy
PERSON
Julie K. Brown
PERSON
Alfredo Rodriguez
PERSON
United States
LOCATION
Harry Reid
PERSON
Joe Biden
PERSON
Eric Trump
PERSON