Epstein Secrets

ng to seal judicial records to ensure that the courts do not sacrifice the public's right of access to the desires of the litigations. See generally Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) (First Amendment and common law right to judicial documents); In re Omnicom Grp., Inc. Sec.

tlement). Neither of the Parties have presented the "specific, on-the-record findings" that establish a compelling reason for sealing or redaction. Lugosch, 435 F.3d at 126. Quite the opposite — the Court initially granted at least 35 letter motions to seal documents, the vast majority with de minimis

emaining documents, the majority of which are those submitted in opposition or support to discovery motions, also qualify.' Citing the broad rule in Lugosch, the court in Alexander Interactive, Inc. v. Adorama, Inc., No. 12 CIV. 6608 PKC JCF, 2014 WL 4346174, at *2 (S.D.N.Y. Sept. 2, 2014), stated that

35 U.S. 589 (1978) 10 Press-Enterprise Co. v. Superior Court, 464 U.S. 501 (1984) 10 Savitt v. Vacco, No. 95-CV-1842(RSP/DRH), 1996 WL 663888 (N.D.N.Y. Nov. 8, 1996) 7 Schiller v. City of New York, No. 04 CIV. 792I(ICMK), 2006 WL 2788256 (S.D.N.Y. Sept. 27, 2006) 7, 12 Sec. and Exch. Conun'n v.

g order is narrowly tailored to achieve that aim."13 " Bernstein v. Bernstein Litowitz Berger & Grossmann LLP, 814 F.3d 132, 139 (2d Cir. 2016). 12 Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 121 (2d Cir. 2006). We observe that our holding in Lugosch relies on the general principle that parties ma

ann LLP, 814 F.3d 132, 139 (2d Cir. 2016). 12 Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 121 (2d Cir. 2006). We observe that our holding in Lugosch relies on the general principle that parties may "be assumed to have supported their papers with admissible evidence and non- frivolous arguments."

bears no possible relation to the controversy or may cause the objecting party prejudice."); Wine Markets Int'l, Inc. v. Bass, 177 F.R.D. 128,133 (E.D.N.Y. 1998) ("Motions to strike are not generally favored, except in relation to scandalous matters."); Alvarado-Morales v. Digital Equip. Corp., 843 F.2

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

HERALD MEDIA COMPANY, ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNOVICH MEDIA Intervenors. ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, 15-CV-7433 (LAP) Ghislaine Maxwell's Opening Brief Ty Gee Adam Mueller HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Den r 2 Tel. A