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987) 4, 5, 8 Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) 4 Miller v. City of Ithaca, No. 10 Civ. 597 (TJM), 2013 WL 12310711 (N.D.N.Y. May 8, 2013) 6 Nixon v. Warner Commc 'us, Inc., 435 U.S. 589 (1978) 4, 5, 6 Scott v. Graham, No. 16 Civ. 2372 (KPF) (JLC), 2016 WL 6804999 (S.D.
Nixon, 435 U.S. at 598 ("[C]ourts have refused to permit their files to serve as reservoirs of libelous statements for press consumption . . . ."); Amodeo II, 71 F.3d at 1051 ("Raw, unverified information should not be as readily disclosed as matters that are verified. Similarly, a court may consider whe
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
ess, the court must determine the weight to be afforded to the presumption and then balance the interest in access against competing considerations. Amodeo II, 71 F.3d at 1050. Competing considerations include, but are not limited to, the reliance interests of those resisting disclosure, the constitutiona
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
documents submitted in connection with, and relevant to, such judicial decision-making are subject to at least some presumption of public access. Amodeo II, 71 F.3d at 1049. 30 Id. at 1050. 31 Id. 32 Id. at 1049. 3 33 In previous decisions, we have identified an important exception to this general
Entities connected to both Southern District of New York and Amodeo II

Jeffrey Epstein
PERSONthe Southern District
LOCATION
Ghislaine Maxwell
PERSONJane Doe
PERSON
George W. Bush
PERSON
Julie K. Brown
PERSON
Alan Dershowitz
PERSON
Paul Cassell
PERSONSecond Circuit
ORGANIZATION
David Boies
PERSONSigrid McCawley
PERSON
Cynthia Nixon
PERSON
Denver
LOCATION
Robert Mueller
PERSON
The New York Times
ORGANIZATIONSweet
PERSONthe Court of Appeals
ORGANIZATION
Larry Page
PERSONR. App
PERSONOnondaga
LOCATION