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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,
holding in Brown. The Circuit made clear that this District Court must engage in its own review with respect to each document and provide notice to the Non-Parties for documents that were not 6 EFTA00074969 CaaM152-a,‘2-0743134o%PleDbtOrfiefiVM30Alle?BOMIV2eafabef746f 22 entitled to the highest presumption
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
Court going forward, should the unsealing move ahead. Of note, and as Plaintiff will explain to the Court, the parties have agreed to notify all of the Non-Parties at once so that we can understand which Non-Parties object to the unsealing before deciding how to proceed with future redactions. Although this wil
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
Court going forward, should the unsealing move ahead. Of note, and as Plaintiff will explain to the Court, the parties have agreed to notify all of the Non-Parties at once so that we can understand which Non-Parties object to the unsealing before deciding how to proceed with future redactions. Although this wil
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
Court going forward, should the unsealing move ahead. Of note, and as Plaintiff will explain to the Court, the parties have agreed to notify all of the Non-Parties at once so that we can understand which Non-Parties object to the unsealing before deciding how to proceed with future redactions. Although this wil
Entities connected to both the Second Circuit's and the Non-Parties

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSON
Colorado
LOCATIONSecond Circuit
ORGANIZATIONJane Doe
PERSONSweet
PERSON
Bradley Edwards
PERSONMaria Farmer
PERSONJeffrey Pagliuca
PERSONLoretta A. Preska
PERSON
Russell Simmons
PERSONSouthern District
LOCATION
Foreman
PERSON
Denver
LOCATIONNon-Parties
ORGANIZATION
the United States District Court
ORGANIZATIONLaura Menninger
PERSON
Alan Dershowitz
PERSONHaddon
PERSON