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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
e. The absence of a response, however, does not end the analysis. Although the Court's Protocol requires consideration of objections from the other Non-Parties yet to be noticed, the Court could (and should) determine, based on the circumstances of the Sealed Materials selected here, that the items are appr
to place Plaintiff's submission into context. DE 153 is Plaintiff's reply which, again quotes from Ms. Maxwell's deposition and references numerous Non-Parties. DE 153-1 contains 7 exhibits. Exhibit I is a portion of Ms. Maxwell's deposition. Exhibit 2 contains a "Flight Log Summary Chart" prepared by Plain
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
ause only Doe 1 and Doe 2 have received notice of potential sealing thus far, and because the first five motions contain the names of various other Non-Parties, Maxwell contends in her objection that the Court cannot unseal any of the first five motions or their related docket entries until each Non-Party
re "unjustified obstacles" or that the public will never have access to these documents -- reflect unjustified criticisms of the Protocol itself and the Second Circuit's decision in Brown, both of which fairly outline the legal process for parties and Non-Parties alike to be heard with respect to unsealing. Notably,
f the judicial function," "not considered a judicial document" and enjoys "no presumption of public access."). Further, in addition to Doe 1, other Non-Parties are included in DE's 185-3, 185-11, 185- 14 and 185-15 each of whom has not yet been notified or had the opportunity to object under this Court's Pr
Cr. 330 (AJN) (the "Criminal Action"). The information implicates Ms. Maxwell's right to due process and fairness in this civil action and affects the Second Circuit's review of the Court's unsealing order of July 23, 2020. Additionally, the information implicates her rights as a criminal defendant guaranteed unde
week per Non-Party to agree to the excerpts to send to them for review. But on balance we agree that having a sense of the number of participating Non-Parties will aid the Court in conducting future proceedings, we have agreed to Plaintiff's suggestion on that front. The parties can submit a proposed modif
0 Cr. 330 (MN) (the "Criminal Action"). The information implicates Ms. Maxwell's right to due process and fairness in this civil action and affects the Second Circuit's review of the Court's unsealing order of July 23, 2020. Additionally, the information implicates her rights as a criminal defendant guaranteed unde
week per Non-Party to agree to the excerpts to send to them for review. But on balance we agree that having a sense of the number of participating Non-Parties will aid the Court in conducting future proceedings, we have agreed to Plaintiff's suggestion on that front. The parties can submit a proposed modif
0 Cr. 330 (MN) (the "Criminal Action"). The information implicates Ms. Maxwell's right to due process and fairness in this civil action and affects the Second Circuit's review of the Court's unsealing order of July 23, 2020. Additionally, the information implicates her rights as a criminal defendant guaranteed unde
week per Non-Party to agree to the excerpts to send to them for review. But on balance we agree that having a sense of the number of participating Non-Parties will aid the Court in conducting future proceedings, we have agreed to Plaintiff's suggestion on that front. The parties can submit a proposed modif
Entities connected to both the Second Circuit's and Non-Parties

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSONthe Southern District
LOCATIONMartindell
PERSON
Colorado
LOCATIONSecond Circuit
ORGANIZATIONSweet
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Cynthia Nixon
PERSONJeffrey Pagliuca
PERSONMaria Farmer
PERSON
Russell Simmons
PERSONLoretta A. Preska
PERSONSouthern District
LOCATION
Foreman
PERSON
Denver
LOCATION
the United States District Court
ORGANIZATIONLaura Menninger
PERSON