Epstein Secrets

tes of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC //: DATE FILED: 3/18/21 20-CR-330 (MN) ORDER ALISON J. NATHAN, District Judge: On February 26, 2021, the Government filed its omnibus memorandum of law opposing Defendants' twelve pre-trial motions. It filed t

f impairing law enforcement or judicial efficiency' and `the privacy interests of those resisting disclosure.' Id. at 120 (quoting United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995) ("Amodeo IT)). I EFTA00031598 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 168 Filed 03/18/21 Page 2 of

in opposition to the Defendant's pre-trial motions is a "judicial document" for purposes of the first element of the Lugosch test. United States v. Amodeo ("Amodeo I"), 44 F.3d 141, 145 (2d Cir. 1995). The Court thus concludes that there is a common law and a First Amendment presumption of access. Id.

fer, and propose redactions to Exhibit 11 of the Government's submission by March 22, 2021. SO ORDERED. Dated: March 18, 2021 New York, New York ALISON J. NATHAN United States District Judge 5 EFTA00031602

Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 9/2/20 20-CR-330 (MN) MEMORANDUM OPINION AND ORDER ALISON J. NATHAN, District Judge: On August 17, 2020, Defendant Ghislaine Maxwell filed a sealed letter motion seeking an Order modifying the protective order in th

f impairing law enforcement or judicial efficiency' and 'the privacy interests of those resisting disclosure.'" Id. at 120 (quoting United States v. Amodeo, 71 F.3d 1044, 1048 (2d Cir.1995) ("Amodeo Ii")). The Government's proposed redactions satisfy this test. First, the Court finds that the defendant

seful in the judicial process," thereby qualifying as a "judicial document" for purposes of the first element of the Lugosch test. United States v. Amodeo ("Amodeo I"), 44 F.3d 141, 145 (2d Cir. 1995). Second, the Court assumes that the common law presumption of access attaches, thereby satisfying the

States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC DATE FILED: 12/3/20 20-CR-330 (MN) ORDER ALISON J. NATHAN, District Judge: On November 25, 2020, counsel for Defendant Ghislaine Maxwell filed a letter request seeking an in camera conference for the prese

f impairing law enforcement or judicial efficiency' and `the privacy interests of those resisting disclosure.' Id. at 120 (quoting United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995) ("Anrodeo II")). EFTA00030910 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 81 Filed 12/03/20 Page 2 of 2

seful in the judicial process," thereby qualifying as a "judicial document" for purposes of the first element of the Lugosch test. United States v. Amodeo ("Amodeo 1"), 44 F.3d 141, 145 (2d Cir. 1995). And while the Court assumes that the common law presumption of access attaches, in balancing competi

thern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 August 21, 2020 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States

New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in opposition to the defendant's letter of August 17, 2020 (the "Defense Letter"), requesting that

ptively accessible, can be kept from the public if their dissemination might 'adversely affect law enforcement interests.") (citing United States v. Amodeo, 71 F.3d 1044, 1050)); see also United States v. Park, 619 F. Supp. 2d 89, 94 (S.D.N.Y. 2009) (holding that the need to "maintain the secrecy of th

2020 TO BE FILED UNDER SEAL VIA EMAIL (SUBMITTED PURSUANT TO SECTION 2(B) OF JUDGE NATHAN'S INDIVIDUAL PRACTICES IN CRIMINAL CASES) The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 C

Court Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: 800 Third Avenue New Yolk, NY 10022 +1 212 957 7600 phone whwtcohensresser cool On behalf of our client, Ghislaine Maxwell, we plan to file a R

ge 3 Here, that lower presumption is far outweighed by the significant privacy interests implicated by the materials at issue. See United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995) ("[t]he privacy interests of innocent third parties ... should weigh heavily in a court's balancing equation").

H A D D O N MORGAN FOREMAN March 9, 2021 The Hon. Alison J. Nathan United States District Court Judge Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, r c Laura A. M

Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Objection to Proposed Redactions of Government's Omnibus Response & Exhibit 5 Dear Judge Nathan: On behalf of defendant Ghislaine Maxwell, we respectfully oppose certain of the redactions proposed by the government to their Omnibus Memorandum

sure of accountability and for the public to have confidence in the administration of justice.'" Lugosch, 435 F.3d at 119 (quoting United States v. Amodeo (Amodeo II), 71 F.3d 1044, 1048 (2d Cir. 1995)). Although the government claims that the items must remain sealed due to an "ongoing investigation,

f impairing law enforcement or judicial efficiency' and 'the privacy interests of those resisting disclosure.'" Id. at 120 (quoting United States v. Amodeo, 71 F.3d 1044, 1048 (2d Cir.1995) ("Amodeo II")). The Government's proposed redactions satisfy this test. First, the Court finds that the defendant

his matter, the Defendant may make unsealing applications to those Courts if she wishes. SO ORDERED. Dated: September 2, 2020 New York, New York ALISON J. NATHAN United States District Judge 5 EFTA00028059

Manle Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Mr. Manley: The Government writes in response to your letter to the Honorable Alison J. Nathan regarding your client and your request for assurances regarding ensuring your client's anonymity in upcoming criminal proceedings, including in do

Second Circuit has explained that 'the public has an especially strong right of access to evidence introduced in trials."' (quoting United States v. Amodeo, 71 F.3d 1044, 1049 (2d Cir. 1995) (internal quotation marks and citation omitted)). Finally, although the Government is mindful of privacy interes