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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
her interests can rise to the level of a compelling interest sufficient to overcome any presumption of right to access. See, e.g., United States v. Longueuil, 567 F. App'x 13, 16 (2d Cir. 2014) (holding that district court properly sealed contested documents "as they reflected sensitive information about
other than plaintiff] who was 17 at this point." Id. 121. None of these questions and answers was used in the summary judgment papers or released by the Second Circuit. The transcript containing this testimony is sealed. 2. The Court should commence proceedings to vindicate the government and plaintiff's violation
Page: EFTA00021863 →nment had no ability legally to obtain the deposition transcripts. In Martindell v. International Telephone and Telegraph Corp., 594 F.2d 291, 293 (2d Cir. 1979), cited with approval in In re Teligent, Inc., 640 F.3d 53, 58 (2d Cir. 2011), the government moved in a civil action to which it was not a par
Page: EFTA00021864 →fairness to the defendants, see id. at 602 n.14. In In reNew York Times Co., 828 F.2d 110 (2d Cir. 1987), cited with approval in United States v. Longueuil, 567 Fed. App'x 13,16 (2d Cir. 2014), Judge Weinstein denied the media's motion to unseal papers filed in connection with an unsuccessful defense mo
Page: EFTA00021866 →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
Page: EFTA00022965 →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
Page: EFTA00022967 →he integrity of criminal investigations and the privacy and safety of witnesses and suspects that are part of those investigations. United States v. Longueuil, 567 F. App'x 13, 16 (2d Cir. 2014) (holding that district court properly sealed contested documents "as they reflected sensitive information about
Page: EFTA00022968 →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.
Page: EFTA00017077 →criminal 4 EFTA00017078 --- PAGE BREAK --- casceamgQAR6nag'49kcnenbt•NeffFiWo*lieZt3&@f2V2f?an§ef61•9f 10 investigations. See United States v. Longueuil, 567 F.App'x 13, 16 (2d Cir. 2014) (finding it was not an abuse of discretion to allow continued sealing of discovery materials that were not judici
Page: EFTA00017079 →Entities connected to both Second Circuit and Longueuil

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSON
Julie K. Brown
PERSON
Bradley Edwards
PERSON
Southern District of New York
ORGANIZATIONJeffrey Pagliuca
PERSON
David Boies
PERSON
Virginia Giuffre
PERSON
George W. Bush
PERSON
Paul Cassell
PERSON
Denver
LOCATION
Colorado
LOCATIONLaura Menninger
PERSON
Cynthia Nixon
PERSON
Lugosch
PERSON
Harvey Weinstein
PERSONSigrid McCawley
PERSONSouthern District
LOCATION