Epstein Secrets

cess to the deposition materials at issue in this case than to the summary judgment materials we ordered unsealed in Brown v. Atwavehc 929 F.3d 41 (2d Cir. 2019), and that her interests outweigh the public's interests. We assume the parties' familiarity with the underlying facts, the procedural history

cCawley, on the briy) Boies Schiller Flexner LLP, Armonk, NY. ADAM MUELLER (Ty Gee, on the brief] Haddon, Morgan and Foreman, P.C., Denver, CO. CHRISTINE N. WALz (Sanford L. Bohrer, on the brief) Holland & Knight LLP, New York, NY, for Intervenors Julie Brown and Miami Honk/ Media Compaig. Appeal from an o

rotected by the Protective Order outweighs any public interest in their publication." (Id., at 9.) Messrs. Dershowitz and Cemovich both appealed to the Second Circuit. (ECF Nos. 500 and 915.) TheaAppeals are currently pending. On May 24, 2016, Plaintiff and Defendant entered into a settlement agreement. Now, the

Herald's motion to intervene and unseal all sealed or redacted docket entries should be granted. Dated: April 6, 2018 Respectfully Submitted, /s Christine N. Walz HOLLAND & KNIGHT LLP Sanford L. Bohrer Christine N. Walz 31 West 52nd Street New York, NY 10019 Telephone: 212.513.3200 Fax: 212.385.9010 Att

hat the district court (or Ms. Maxwell or Ms. M) unjustifiably delayed public access to the summary judgment papers. This is incorrect. In Lugosch the Second Circuit was understandably impatient with the district court's delay in acting on two newspapers' motion to intervene to unseal the summary judgment filing

utah.edu) United States District Court for the Sigrid S. McCawley Southern District of New York ([email protected]) (via United States mail) Christine N. Walz ([email protected]) Madelaine J. Harrington ([email protected]) Sanford L. Bohrer ([email protected]) Andrew G. Celli

rivacy interests of non- parties ... represents a legitimate basis for sealing judicial documents"). B. Effect of Previous Unsealing of Documents by Second Circuit Plaintiff claims that if a document is already public in another context, then it should be unsealed. She cites no law for this proposition, which

00 Ft. Lauderdale. FL 33301 Bradley J. Edwards Stan J. Pottinger EDWARDS POTTINGER LLC 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 Christine N. Walz Sanford L. Bohrer Cynthia A. Gierhart HOLLAND & KNIGHT LLP 31 West 52' Street New York, NY 10019 Nicholas J. Lewin Paul M. Krieger ICRIEGER K

Stan J. Pottinger EDWARDS POTTINGER LLC 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad @pathtojustice.com [email protected] Christine N. Walz HOLLAND & KNIGHT LLP 31 West 52nd Street New York, NY 10019 [email protected] Paul G. Cassell 383 S. University Street Salt Lake City,

otions 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 supporting continued sealing; and (c

cited with approval in SEC v. TheStreet.com, 273 F.3d 222, 232 (2d Cir. 2001), which was cited with approval in Brown, 929 F.3d at 51 n.40. Notably the Second Circuit in Brown held that redactions of sensitive, private information disclosed by witnesses in depositions because of "a strong expectation of continued

Case No.: 15-cv-07433-RWS INTERVENORS' JULIE BROWN AND MIAMI HERALD MEDIA CO.'S RESPONSE TO MAXWELL'S OBJECTIONS TO UNSEALING Sanford L. Bohrer Christine N. Walz 31 West 52nd Street New York, NY 10019 Telephone: 212.513.3200 Fax: 212.385.9010 Attorneys for Intervenors Julie Brown and Miami Herald Media C

was not valid, as implemented. See Brown v. Maxwell, 929 F.3d 41 (2d. Cir. 2019). Therefore, Martindell is not applicable. Further, in later cases, the Second Circuit limited Martindell's ruling to cases involving documents that were not "judicial documents" subject to a presumption of access. See United States v.

and Law Firms Counsel for Interveners Julie Brown & Miami Herald Media Company: HOLLAND & KNIGHT LLP, 31 West 52nd Street, New York, NY 10019, By: Christine N. Walz, Esq., Sanford L. Bohrer, Esq. Counsel for Plaintiff : BOIES SCHILLER & FLEXNER LLP, 401 E. Las Olas Boulevard, Suite 1200, Fort Lauderdale, FL 3

ep't of Justice, 312 F.3d 100, 106 (2d Cir. 2002), vacated and remanded, 541 U.S. 970, 124 S.Ct. 1874, 158 L.Ed.2d 464 (2004), aff'd, 380 F.3d 110 (2d Cir. 2004) (per curiam) (witnesses and third parties "possess strong privacy interests, because being identified as part of a law enforcement investigati