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overnment's proposed redactions on pages 1-128 all relate to materially inaccurate statements made by a prosecutor for the government to Chief Judge McMahon. They also relate to a sealed proceeding in which the government circumvented decades-old precedent in this Circuit which held that civil litigatio
Page: EFTA00029844 →e and its Exhibits are clearly "judicial documents" presumptively subject to the public access rights under both the common law and First Amendment. Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119 (2d Cir. 2006); Brown v. Maxwell, 929 F.3d 41, 49 (2d Cir. 2019). Ms. Maxwell also specifically asser
Page: EFTA00029844 →nection with a protective order in a different case. The judge who presided over the civil case passed away in March 2019, and so then- Chief Judge McMahon heard the Government's ex parte application. In a hearing on March 26, 2019, Judge McMahon explained that she believed the Second Circuit's decision
to a court's ruling, Second Circuit precedent creates a strong presumption that they will be made public notwithstanding any protective order. See Lugosch, 435 F.3d at 126. These are not remote or theoretical possibilities. Each of them predictably came to pass in this case. See Brown, 929 F.3d at 48
nection with a protective order in a different case. The judge who presided over the civil case passed away in March 2019, and so then- Chief Judge McMahon heard the Government's ex parte application. In a hearing on March 26, 2019, Judge McMahon explained that she believed the Second Circuit's decision
to a court's ruling, Second Circuit precedent creates a strong presumption that they will be made public notwithstanding any protective order. See Lugosch, 435 F.3d at 126. These are not remote or theoretical possibilities. Each of them predictably came to pass in this case. See Brown, 929 F.3d at 48
nection with a protective order in a different case. The judge who presided over the civil case passed away in March 2019, and so then- Chief Judge McMahon heard the Government's ex parte application. In a hearing on March 26, 2019, Judge McMahon explained that she believed the Second Circuit's decision
to a court's ruling, Second Circuit precedent creates a strong presumption that they will be made public notwithstanding any protective order. See Lugosch, 435 F.3d at 126. These are not remote or theoretical possibilities. Each of them predictably came to pass in this case. See Brown, 929 F.3d at 48
nection with a protective order in a different case. The judge who presided over the civil case passed away in March 2019, and so then- Chief Judge McMahon heard the Government's ex parte application. In a hearing on March 26, 2019, Judge McMahon explained that she believed the Second Circuit's decision
to a court's ruling, Second Circuit precedent creates a strong presumption that they will be made public notwithstanding any protective order. See Lugosch, 435 F.3d at 126. These are not remote or theoretical possibilities. Each of them predictably came to pass in this case. See Brown, 929 F.3d at 48
nection with a protective order in a different case. The judge who presided over the civil case passed away in March 2019, and so then- Chief Judge McMahon heard the Government's ex parte application. In a hearing on March 26, 2019, Judge McMahon explained that she believed the Second Circuit's decision
to a court's ruling, Second Circuit precedent creates a strong presumption that they will be made public notwithstanding any protective order. See Lugosch, 435 F.3d at 126. These are not remote or theoretical possibilities. Each of them predictably came to pass in this case. See Brown, 929 F.3d at 48
Entities connected to both Colleen McMahon and Lugosch

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONSecond Circuit
ORGANIZATION
Julie K. Brown
PERSON
United States
LOCATION
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
David Boies
PERSON
Prince Andrew
PERSONMartindell
PERSONOnondaga
LOCATION
Supreme Court
ORGANIZATION
George W. Bush
PERSON
Carpenter
PERSON
Alison J. Nathan
PERSONSweet
PERSON
Michael Cohen
PERSONJeffrey Pagliuca
PERSON
Virginia Giuffre
PERSON
Colorado
LOCATION