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f the persons whose intimate relations may thereby be 40 EFTA00075522 Case 20-2413, Document 40, 08/20/2020, 2913550, Page47 of 74 disclosed."); Amodeo 11,71 F.3d at 1050 (" [T]he privacy interests of innocent third parties . . . should weigh heavily in a court's balancing equation."). This Court h
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
or not to enter [a] protective order"). The fact that Juror No. 50 filed these pleadings does not make them "judicial documents." United States v. Amodeo ("Amodeo I'), 44 F.3d 141, 145 (2d Cir. 1995) ("We think that the mere filing of a paper or document with the court is insufficient to 54 EFTA0015
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
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,
Page: EFTA00029845 →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
Page: EFTA00029846 →Entities connected to both Amodeo and Loretta A. Preska

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSONSecond Circuit
ORGANIZATION
Julie K. Brown
PERSON
David Boies
PERSONSigrid McCawley
PERSON
Prince Andrew
PERSON
Virginia Giuffre
PERSON
Bradley Edwards
PERSON
Alan Dershowitz
PERSONMartindell
PERSONSweet
PERSON
United States
LOCATIONJeffrey Pagliuca
PERSON
Colorado
LOCATION
Lugosch
PERSON
Denver
LOCATION
George W. Bush
PERSONthe Southern District
LOCATIONTy Gee
PERSON