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sistance to discovery on grounds of privacy, confidentiality, secrecy, sensitivity and embarrassment. Even if Lugosch could overrule Martindell and Gambale with respect to the strong presumption against access when there is reasonable reliance on a protective order, the Lugosch 5In Lugosch, this Court
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
irst, courts in this Circuit have routinely ordered unsealing of documents in cases with protective orders or confidentiality provisions. See, e.g., Gambale v. Deutsche Bank AG, 377 F.3d 133, 143 (2d Cir. 2004) (unsealing judicial document despite party's claim that it had settled claim to "avoid public
Page: EFTA00017076 →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 →a July 29, 2020 Page 2 courts have recognized, temporary stays of unseal orders are appropriate so that "[t]he genie is [not] out of the bottle," Gambale v. Deutsche Bank AG, 377 F.3d 133, 144 (2d Cir. 2004), before the interested parties have an opportunity to seek review of the orders. See, e.g., Un
Page: EFTA00021862 →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 →Entities connected to both Gambale and Longueuil

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSON
Julie K. Brown
PERSONMartindell
PERSON
Cynthia Nixon
PERSON
Denver
LOCATIONTy Gee
PERSON
Virginia Giuffre
PERSONSigrid McCawley
PERSONSecond Circuit
ORGANIZATIONSweet
PERSONAmodeo
PERSONChristine N. Walz
PERSON
United States
LOCATION
Sanford L. Bohrer
PERSON
Lugosch
PERSON