Epstein Secrets

xwell's failure is especially jarring in light of the public's interest in this litigation, which involved voluminous documents and testimony about Jeffrey Epstein's transcontinental sex-trafficking operation and documents concerning various public agencies' utter failure to protect and bring justice to his vict

ed, a quick 6 EFTA00075033 CasqaMglitg6taagtalmeabgineAFIVA04146legiteaMbbef-138f 24 Google search of Doe 1 or Doe 2's last name, plus the term "Epstein" or "Maxwell," reveals much of the information about those Non-Parties that is currently under seal. The only argument that Maxwell makes concernin

nvolved voluminous documents and testimony about Jeffrey Epstein's transcontinental sex-trafficking operat

investigation "surrounding the alleged conduct of Mr. Epstein," provides no other information, yet states in a

o. 02 CIV. 4483 RCC/MHD, 2006 WL 3016311 (S.D.N.Y. Oct. 23, 2006) 5 In re Pannalat Sec. Litig., 258 F.R.D. 236 (S.D.N.Y. 2009) passim Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) 10, 11, 12 Lytle v. JPMorgan Chase, 810 F. Supp. 2d 616 (S.D.N.Y. 2011) passim Martindell v. Intl Tel

Filed 04/06/18 Page 2 of 21 TABLE OF CONTENTS TABLE OF AUTHORITIES ii PRELIMINARY STATEMENT 1 I. INTERVENORS' COVERAGE OF ALLEGATIONS AGAINST JEFFREY EPSTEIN AND GHISLAINE MAXWELL 2 II. THE OVERBROAD SEALING ORDER AND PRIOR ATTEMPTS TO UNSEAL 3 III. THE ORDER DENYING THE MOTIONS TO UNSEAL 6 ARGUMEN

ve journalist at the Miami Herald with over twenty years of experience. For over three years, the Miami Herald has reported on and investigated Mr. Epstein and others who were involved in the sexual abuse of underage girls. Recent court filings, both in federal and state court, have raised new allegatio

I. INTERVENORS' COVERAGE OF ALLEGATIONS AGAINST JEFFREY EPSTEIN AND GHISLAINE MAXWELL 2 II. THE OVERB

tions between those law enforcement agencies and Mr. Epstein's legal defense team, and the ultimate decision

udicial records to ensure that the courts do not sacrifice the public's right of access to the desires of the litigations. See generally Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) (First Amendment and common law right to judicial documents); In re Omnicom Grp., Inc. Sec. Litig., No. 02

remaining sealed materials. I. BACKGROUND A. Jeffrey Epstein's Conviction and the CVRA Suit The origins of this

Jeffrey Epstein's Conviction and the CVRA Suit The origins of this case lie in a decade-old criminal proceeding against financier Jeffrey Epstein ("Epstein"). On June 30, 2008, Epstein pleaded guilty to Florida state charges of soliciting, and procuring a person under the age of eighteen for, prostitut

remaining sealed materials. I. BACKGROUND A. Jeffrey Epstein's Conviction and the CVRA Suit The origi

narrowly tailored to achieve that aim."13 " Bernstein v. Bernstein Litowitz Berger & Grossmann LLP, 814 F.3d 132, 139 (2d Cir. 2016). 12 Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 121 (2d Cir. 2006). We observe that our holding in Lugosch relies on the general principle that parties may "be assumed

ing factual information: I. Grand jury subpoenas were issued to an entity ("Recipient") after the Government opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. The Recipient concluded that it could not turn over materials responsive to the grand jury subpoena absent a

t opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. The Recipi

overnment opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. Th

The Court's decision to adopt the Government's proposed redactions is guided by the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Under this test, the Court must: (i) determine whether the documents in question are "judicial documents;"

ing factual information: I. Grand jury subpoenas were issued to an entity ("Recipient") after the Government opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. The Recipient concluded that it could not turn over materials responsive to the grand jury subpoena absent a

t opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. The Recipi

overnment opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. Th

The Court's decision to adopt the Government's proposed redactions is guided by the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Under this test, the Court must: (i) determine whether the documents in question are "judicial documents;"

ithvillazoccom suzanne.kowalski@smithvillazoccom Jeffrey S. Pagliuca [email protected] nsimmons@hmflaw

fore November 22, 2021, and to justify any requested redactions by reference to the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) (Signed by Judge Alison J. Nathan on 11/19/21)(jw) 1:20-cr-00330-AJN-1 Notice has been electronically mail

up to batteries untill we find out where she is." "SHE'S HERE in Massachusetts ?! The bitch #GhislaineMaxwell who #SexTrafficked young girls for #Epstein ?!?! Why the hell isn't she being brought in for questioning @ManchesterMAPD ?! WE DO NOT WANT HER HERE! #SleezyLeach She is CLOSE ENOUGH to me, I

uments under seal if "countervailing factors" in the common law framework or "higher values" in the First Amendment framework so demand. Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 124 (2d Cir. 2006); see also Unites States v. Wey, 256 F. Supp. 3d 355, 411 (S.D.N.Y. 2017) (Nathan, J.) (granting motion

up to batteries untill we find out where she is." "SHE'S HERE in Massachusetts ?! The bitch #GhislaineMaxwell who #SexTrafficked young girls for #Epstein ?!?! Why the hell isn't she being brought in for questioning @ManchesterMAPD ?! WE DO NOT WANT HER HERE! #SleezyLeach She is CLOSE ENOUGH to me, I

uments under seal if "countervailing factors" in the common law framework or "higher values" in the First Amendment framework so demand. Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 124 (2d Cir. 2006); see also Unites States v. Wey, 256 F. Supp. 3d 355, 411 (S.D.N.Y. 2017) (Nathan, J.) (granting motion