Epstein Secrets

onsidered and vacated. 25 EFTA00791894 Case 18-2868, Document 141, 03/15/2019, 2519388, Page27 of 27 Respectfully submitted, s/ Ty Gee Ty Gee Laura Menninger Adam Mueller HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 Tel 303.831.7364 [email protected]; [email protected]; a

nt third parties as well as those of defendants that may be harmed by disclosure . . . should weigh heavily in a court's balancing equation.. .."); Amodeo, 71 F.3d at 1050 ("We have previously held that the privacy interests of innocent third parties . . . should weigh heavily in a court's balancing e

15-cv-07433-LAP Ms. Maxwell's Objections to Unsealing Docket Entries 143. 173. and 199 and to Unsealing Docket Entries 164 and 230 at This Time. Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 EFTA00075004 CageaUlg0caAIDer0dthhilfii igl5

rmance of the judicial function and useful in the judicial process in order for it to be designated a judicial document. Id. Brown was building on Amodeo /'s holding when it said, "As our precedent makes clear, a court mperforrn[s] the judicial function' ... when it rules on motions currently before i

, By: Paul G. Cassell, Esq. Counsel for Defendant Ghislaine Maxwell: HADDON, MORGAN AND FOREMAN, P.C., 150 East 10th Avenue, Denver, CO 80203, By: Laura A. Menninger, Esq., Jeffrey S. Pagliuca, Esq., Ty Gee, Esq. Counsel for Intervenor Michael Cemovich: RANDAZZA LEGAL GROUP, PLLC, 100 Pearl Street, 14th Floor,

r district court to edit and redact judicial document to allow access to appropriate portions after weighing competing interests); United States v. Amodeo. 71 F.3d 1044 (2d Cir. 1995) ("Amodeo 11") (presumption of access afforded to particular document filed with court varies with document's relevance

Inc., 121 F.3d 818 (2d Cir. 1997) (sealing file pursuant to confidentiality agreement between parties was not abuse of discretion); United States v. Amodeo, 44 F.3d 141 (2d Cir. 1995) ("Amodeo I") (finding it proper for district court to edit and redact judicial document to allow access to appropriate p

15-cv-07433-LAP \ Is. Maxwell's Objections to Unsealing Docket Entries 143, 173, and 199 and to Unsealing Docket Entries 164 and 230 at This Time. Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 303.831.7364 EFTA00022960 --- PAGE BREAK -

h dispositive motions such as motions for dismissal or summary judgment." Brown v. Maxwell, 929 F.3d 41, 50 (2d Cir. 2019) (citing United States v. Amodeo, 71 F.3d 1044, 1049-50 (2d Cir. 1995) ("Amodeo II")); (b) any minimum presumption of public access is subject to many countervailing interests suppo