Epstein Secrets

AND Plaintiff demands a trial by jury of all issues properly triable by jury in this action. Respectfully submitted, Dated: June 20. 2016 By: Is/ Thomas Francis Meagher Thomas Francis Meagher SDNY Bar Code TM6707 One Palmer Square Princeton, New Jersey 08542 Telephone: (609) 558-1500 tmeagher@thomasfmeagheresq.

al nature, and identification of Plaintiff would pose a risk of retaliatory physical harm to her and to others. Exh. A. All of the ten factors that the Second Circuit articulated as relevant to this analysis favor anonymity, especially factors 1-4, 7, and 10 (e.g., factors one and two: "whether the litigation invo

AND Plaintiff demands a trial by jury of all issues properly triable by jury in this action. Respectfully submitted, Dated: June 20. 2016 By: Is/ Thomas Francis Meagher Thomas Francis Meagher SDNY Bar Code TM6707 One Palmer Square Princeton, New Jersey 08542 Telephone: (609) 558-1500 tmeagher@thomasfmeagheresq.

al nature, and identification of Plaintiff would pose a risk of retaliatory physical harm to her and to others. Exh. A. All of the ten factors that the Second Circuit articulated as relevant to this analysis favor anonymity, especially factors 1-4, 7, and 10 (e.g., factors one and two: "whether the litigation invo

tweighs the public’s interest in knowing their identity and any prejudice to the defendants. Sealed Plaintiff-v. Sealed Defendant, 537 F.3d 185, 189 (2d Cir. 2008). This litigation involves matters that are highly sensitive and of a personal nature, and identification of Plaintiff would pose a risk of reta

onal nature, and identification of Plaintiff would pose a risk of retaliatory physical harm to her and to others. Exh. A. All of the ten factors that the Second Circuit articulated as relevant to this analysis favor anonymity, especially factors 1-4, 7, and 10 (e.g., factors one and two: “whether the litigation invol

EMAND Plaintiff demands a trial by jury of all issues properly triable by jury in this action. Respectfully submitted, Dated: June 20, 2016 By: /s/ Thomas Francis Meagher Thomas Francis Meagher SDNY Bar Code TM6707 One Palmer Square Princeton, New Jersey 08542 Telephone: (609) 558-1500 [email protected]