Epstein Secrets

e minimally redacted material was subject to a "strong presumption" of access under the First Amendment and the common law. Id. at 47 & n.12 (citing Lugosch, 435 F.3d at 121-22). The deposition material at issue here, however, was not submitted to the district court in connection with summary judgment

order unsealing the deposition material, including Ms. Maxwell's April 2016 deposition transcript. On July 23, over Ms. Maxwell's objection, Judge Preska —who is presiding over the civil case and the litigation about the unsealing of the district court filings —ordered the complete unsealing of Ms. M

CM/ECF, which will send notification of the filing to all counsel of record. I also certify that I mailed a copy of the opening brief to: The Hon. Loretta A. Preska District Judge United States District Court for the Southern District of New York (via United States mail) s/ Nicole Simmons 43 EFTA00075525

t "[b]efore any such common law right can attach, however, a court must first conclude that the documents at issue are indeed `judicial documents.' Lugosch, 435 F.3d at 119. "Once the court has determined that the documents are judicial documents and that therefore a common law presumption of access at

oceeds of a heroin trafficking scheme by structuring financial transactions. 128 F.3d at 41. Over the defense's objection, the district court (Judge Preska) dismissed for cause a potential juror who admitted that she "had at one time engaged in the `structuring' of cash transactions." Id. at 42. On app

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

on at Pages 129-134 The government proposes, at pages 129-134, to redact only certain portions of Ms. Maxwell's sealed deposition testimony. Judge Preska has ruled that certain questions and answers are still under seal and subject to the Protective Order in the case. In Ms. Maxwell's Motions, we li