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nt third parties as well as those of defendants that may be harmed by disclosure . . . should weigh heavily in a court's balancing equation.. .."); Amodeo, 71 F.3d at 1050 ("We have previously held that the privacy interests of innocent third parties . . . should weigh heavily in a court's balancing e
at the district court (or the appellees) unjustifiably delayed resolution of the unseal motions and its abuse of discretion in failing to adhere to the Second Circuit's "clear[]"3 precedent. We respectfully submit that neither conclusion warrants the extraordinary action being contemplated by the panel. A. The dist
"are at the lowest." United States v. Huntley, 943 F. Supp. 2d 383, 387 (E.D.N.Y. 2013) (internal quotation marks and citations omitted); see also Amodeo 11,71 F.3d at 1051 ("[A] court may consider whether the nature of the materials is such that there is a fair opportunity for the subject to respond
jections to unsealing. Maxwell's objections are inconsistent with the Court's May I, 2020 Order, the presumption of public access to documents, and the Second Circuit's instructions when it remanded this matter nearly a year ago. Further, Maxwell's objections are extraordinarily general and vague, and cannot defeat
rmance of the judicial function and useful in the judicial process in order for it to be designated a judicial document. Id. Brown was building on Amodeo /'s holding when it said, "As our precedent makes clear, a court mperforrn[s] the judicial function' ... when it rules on motions currently before i
19) (emphasis supplied; footnote omitted; quoting United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995) ("Amodeo r')). Amodeo I, the inception of the Second Circuit's principle that a file stamp is not a judicial-document talisman, is instructive. There an appointed Court Officer tasked parties; DE 204-1 referenc
Entities connected to both Amodeo and the Second Circuit's

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Julie K. Brown
PERSONSecond Circuit
ORGANIZATIONMartindell
PERSONthe Southern District
LOCATION
Lugosch
PERSON
Scarlett Johansson
PERSON
Cynthia Nixon
PERSON
David Boies
PERSON
Prince Andrew
PERSON
Colorado
LOCATIONSweet
PERSONOnondaga
LOCATION
George W. Bush
PERSON
Bradley Edwards
PERSON
Virginia Giuffre
PERSONJane Doe
PERSON
Audrey Strauss
PERSON