Epstein Secrets

—and the Court in its Order to Show Cause—rested heavily on Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). With respect, neither Lugosch nor any of the other 6 EFTA00791875 Case 18-2868, Document 141, 03/15/2019, 2519388, Page8 of 27 Second Circuit cases supports the position the

the parties. The Order to Show Cause rests on a number of premises that we respectfully submit are flawed. As the Court noted in the Order, under Lugosch a" strong presumption of access" attaches to documents submitted to a court for its consideration in a summary judgment motion. Doc.138 at 2. But a

rsons: The Hon. Robert W. Sweet Paul G. Cassell District Judge ([email protected]) 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 (madelaine.har

by email with proposed redactions. The Government's proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although the Government's motions in limine are judicial documents subject to the common l

U.S. Department of Justice United States Attorney Southern District of New York The Silvio!. Mollo Building One Saint Andrew's Plaza New York, New York 10007 October 18, 2021 BY ECF The Honorable Alison J. Natha

to file a redacted version this letter motion. The proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although this letter motion is a judicial document subject to the common law presumption o

U.S. Department of Justice United States Attorney Southern District of New York The SihioJ. Mollo Building One Saint Andrew's Plaza New York. New York 10007 November 18, 2021 BY E-MAIL The Honorable Alison J. Na

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

cord. 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 Case 20-2413, Document 40. 08/20/2020. 2913550. Page50 of 74 Attachment

et on or before November 22, 2021, and to justify any requested redactions by reference to the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) (Signed by Judge Alison J. Nathan on 11/19/21)(jw) 1:20-cr-00330-AJN-1 Notice has been elec

to this e- mail because the mail box is unattended. ***NOTE TO PUBLIC ACCESS USERS••• There is no charge for viewing opinions. U.S. District Court Southern District of New York Notice of Electronic Filing The following transaction was entered on 11/19/2021 at 11:21 AM EST and filed on 11/19/2021 Case Name: US

and third parties referenced in the document. These proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Today the Government is submitting to the Court by email its proposed redactions to Exhibi

U.S. Department of Justice United States Attorney Southern District of New York BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse May 20, 2