Epstein Secrets

H A D D O N MORGAN FOREMAN August 17, 2020 VIA EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: Request to Mo

r seal, as exhibits 1-10. Although marked by the government as "Confidential," the Materials are not "Confidential" as that term has been defined by the Second Circuit. They consist of ex pane pleadings filed by the government, ex pane transcripts, and ex pane rulings. Boies, Schiller & Flexner ("BSF') lawyers, coo

iami Herald appealed on September 28, 2018. On July 3, 2019 the Second Circuit reversed Judge Sweet's ruling. Brown v. Maxwell, 929 F.3d 41, 44-45 (2d Cir. 2019). Upon the issuance of the mandate, on August 9, 2019, it largely unsealed the summary judgment materials to the public and the press and reman

rn District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 February 28, 2019 TO BE FILED UNDER SEAL VIA EMAIL The Honorable Sarah Netburn United States District Court Southern District of New York United States Courthouse New York, New York 10007 Re: I

ages of litigation—"a court may properly permit modification of the order." Id. (citing In re "Agent Orange" Prod. Liab. Litig., 821 F.2d 139, 147 (2d Cir. 1987)); see also Allen v. City of New York, 420 F.Supp.2d 295, 301 (S.D.N.Y. 2006) (Mag. J. Gorenstein) (analyzing the differently-situated interes

Haddon, Morgan and Foreman. r.c Jeffrey Paglluca HADDON MORGAN FOREMAN pm August 24, 2020 VIA EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 150 East 10th Aven

urt is required to determine whether any countervailing interests outweigh the presumptive right to public access. M. Maxwell, 929 F.3d 41, 49-50 (2d Cir. 2019). Frankly, Ms. Maxwell does not believe that the government has established a countervailing interest compelling enough to justify continued s