Epstein Secrets

the protections afforded the parties and non-parties under this Court's right-to-access jurisprudence. The appellants Miami Herald, Dershowitz and Cernovich —and the Court in its Order to Show Cause—rested heavily on Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). With respect, neither

April 2017 he stipulated to dismissal of his appeal without prejudice. In July 2017 he moved to reinstate his appeal and to consolidate it with Mr. Cernovich's appeal. Merits briefing concluded by early 2018. Supplemental briefing was concluded by April 2018. Discussion None of the appellants is entitle

ated. 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]; [email protected]

moved to intervene, seeking to unseal three do l. that, he argues, demonstrate that invented the accusations against him. On January 19, 2017, Cernovich, an independent blogger and self-described "popular political journalist,"7 moved to intervene, seeking to unseal the summary judgment record, a

ine J. Harrington, New York, NY, on the brief), Holland & Knight LLP, Miami, FL, for Intervenors-Appellants Julie Brown and Miami Herald. Ty Gee (Adam Mueller, on the brief), Haddon, Morgan and Foreman, P.C., Denver, CO, for Defendant-Appellee Ghislaine Maxwell. Paul G. Cassell (Sigrid S. McCawley,

d, and Dershowitz joined his motion. On April 6, 2018, after the case had settled, the Herald moved to intervene and unseal , an' 7 Br. Appellant (Cernovich) 4. 8 EFTA00092315 the entire docket. The District Court granted each of these motions to intervene, but denied the related requests to unseal i

ine J. Harrington, New York, NY, on the brief), Holland & Knight LLP, Miami, FL, for Intervenors-Appellants Julie Brown and Miami Herald. TY GEE (Adam Mueller, on the brief), Haddon, Morgan and Foreman, P.C., Denver, CO, for Defendant-Appellee Ghislaine Maxwell. 3 EFTA00092310 PAUL G. CASSELL (Sigrid