Epstein Secrets

v. Indyke, Case No. 19-cv-10475-LGS See, e.g., wants Ghislaine Maxwell to `rot in jail," NY Post (Dec. 4, 2019); Andrew Denney and Bruce Golding, "Jeffrey Epstein's no-bail ruling may encourage more accusers to come forward," NY Post (July 18, 2019) ("McCawley wouldn't identify her new clients but said she enco

ted pleadings involve Plaintiff's effort which were not and should not have been relevant to Plaintiffs false claim that she was sexually abused by Epstein as a minor. The Second Circuit in Brown itself redacted from the summary judgment pleadings and exhibits all of Ms. Maxwell's deposition answers in

o tnsealinu Sealed Materials Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN,

l the questions, lawsuit filed a lawsuit against Mr. Epstein to produce In fact, in connection with her cur

00 Ft. Lauderdale. FL 33301 Bradley J. Edwards Stan J. Pottinger EDWARDS POTTINGER LLC 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 Christine N. Walz Sanford L. Bohrer Cynthia A. Gierhart HOLLAND & KNIGHT LLP 31 West 52' Street New York, NY 10019 Nicholas J. Lewin Paul M. Krieger ICRIEGER K

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

Herald's motion to intervene and unseal all sealed or redacted docket entries should be granted. Dated: April 6, 2018 Respectfully Submitted, /s Christine N. Walz HOLLAND & KNIGHT LLP Sanford L. Bohrer Christine N. Walz 31 West 52nd Street New York, NY 10019 Telephone: 212.513.3200 Fax: 212.385.9010 Att

, Denver, CO 80203, By: Laura A. Menninger, Esq., Jeffrey S. Pagliuca, Esq., Ty Gee, Esq. Counsel for Int

and Law Firms Counsel for Interveners Julie Brown & Miami Herald Media Company: HOLLAND & KNIGHT LLP, 31 West 52nd Street, New York, NY 10019, By: Christine N. Walz, Esq., Sanford L. Bohrer, Esq. Counsel for Plaintiff : BOIES SCHILLER & FLEXNER LLP, 401 E. Las Olas Boulevard, Suite 1200, Fort Lauderdale, FL 3

British tabloids, described Maxwell's alleged role as someone who recruited or facilitated the recruitment of young females for sexual activity with Jeffrey Epstein ("Epstein"), that she, M, had been interviewed by the Federal Bureau of Investigation ("FBI") in 2011, and that she had discussed Maxwell's involv

described Maxwell's alleged role as someone who recruited or facilitated the recruitment of young females for sexual activity with Jeffrey Epstein ("Epstein"), that she, M, had been interviewed by the Federal Bureau of Investigation ("FBI") in 2011, and that she had discussed Maxwell's involvement in t

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

ffrey 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, prostitu

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

from the United States District Court for the Southern District of New York (Robert W. Sweet, Judge). Attorneys and Law Firms Sanford L. Bohrer (Christine N. Walz, Madelaine J. Harrington, New York, NY, on the brief), Holland & Knight LLP, Miami, FL, for Intervenors-Appellants Julie Brown and Miami Herald.

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

er concurs in this opinion except insofar as it orders the immediate unsealing of the summary judgment record without a remand. SANFORD L. BOHRER (Christine N. Walz, Madelaine J. Harrington, New York, NY, on the brief), Holland & Knight LLP, Miami, FL, for Intervenors-Appellants Julie Brown and Miami Herald.

2 of 27 IN THE UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT Plaintiff-Appellee, v. GHISLAINE MAXWELL, Defendant, v. SHARON CHURCHER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, Intervenors-Appellants No. 18-2868 Appellee Maxwell's Motion to Reconsider and Vacate th

AXWELL, Defendant, v. SHARON CHURCHER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD MEDIA

SLAINE MAXWELL, Defendant, v. SHARON CHURCHER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD

utah.edu) United States District Court for the Sigrid S. McCawley Southern District of New York ([email protected]) (via United States mail) Christine N. Walz ([email protected]) Madelaine J. Harrington ([email protected]) Sanford L. Bohrer ([email protected]) Andrew G. Celli

IN THE UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT Plaintiff-Appellee, v. GHISLAINE MAXWELL, Defendant, v. SHARON CHURCHER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, Intervenors-Appellants No. 18-2868 Appellee Maxwell's Response to Order to Show Cause E

AXWELL, Defendant, v. SHARON CHURCHER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD MEDIA

SLAINE MAXWELL, Defendant, v. SHARON CHURCHER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD

ng persons: The Hon. Robert W. Sweet District Judge United States District Court for the Southern District of New York (via United States mail) Christine N. Walz ([email protected]) Madelaine J. Harrington ([email protected]) Sanford L. Bohrer ([email protected]) Paul G. Cassell

Case No.: 15-cv-07433-RWS INTERVENORS' JULIE BROWN AND MIAMI HERALD MEDIA CO.'S RESPONSE TO MAXWELL'S OBJECTIONS TO UNSEALING Sanford L. Bohrer Christine N. Walz 31 West 52nd Street New York, NY 10019 Telephone: 212.513.3200 Fax: 212.385.9010 Attorneys for Intervenors Julie Brown and Miami Herald Media C

and powerful. Framing allegations of sexual abuse as "private" protects perpetrators at the expense of victims. The Miami Herald's coverage of Mr. Epstein's and his associates' alleged crimes has nothing to do with consensual sexual preferences and everything to do with the abuse of young girls, whethe

pense of victims. The Miami Herald's coverage of Mr. Epstein's and his associates' alleged crimes has nothing

es 164 and 230 at This Time. Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN,

Stan J. Pottinger EDWARDS POTTINGER LLC 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad @pathtojustice.com [email protected] Christine N. Walz HOLLAND & KNIGHT LLP 31 West 52nd Street New York, NY 10019 [email protected] Paul G. Cassell 383 S. University Street Salt Lake City,

the Southern District of New York, and the Attorney General for the U.S. Virgin Islands, that investigations surrounding the alleged conduct of Mr. Epstein survive his death. It is unclear who are witnesses or targets of any investigation. These ongoing investigations are a powerful countervailing inter

ROSEMARY S. POOI.ER, REENA RAGGI, Circuit Judges. Phrinifff-Appellee, 20-2413-cv v. GHISLAINE MAXWELL, Defendant-Appellant, SHARON CHURC:HER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, MICHAEL CERNOVICH, DBA CERNOVICH MEDIA, Intervenors. EFTA00018289 --- PAGE BREAK --- C

cCawley, on the briy) Boies Schiller Flexner LLP, Armonk, NY. ADAM MUELLER (Ty Gee, on the brief] Haddon, Morgan and Foreman, P.C., Denver, CO. CHRISTINE N. WALz (Sanford L. Bohrer, on the brief) Holland & Knight LLP, New York, NY, for Intervenors Julie Brown and Miami Honk/ Media Compaig. Appeal from an o