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owitz is a criminal defense lawyer and retired professor at Harvard Law School. In or about 2006, Mr. Dershowitz joined a defense team assembled by Jeffrey Epstein, a financier who was then under investigation for having sex with underage girls. In 2008, Mr. Epstein pleaded guilty to state charges of solicitati
z joined a defense team assembled by Jeffrey Epstein, a financier who was then under investigation for having sex with underage girls. In 2008, Mr. Epstein pleaded guilty to state charges of solicitation of prostitution and solicitation EFTA00802948 Case 1:15-cv-07433-RWS Document 956 Filed 12/03/18 P
r. Dershowitz joined a defense team assembled by Jeffrey Epstein, a financier who was then under investiga
ion for having sex with underage girls. In 2008, Mr. Epstein pleaded guilty to state charges of solicitation o
for over two years. But, because this Court has thrice denied applications for such disclosure (once when made by Mr. Dershowitz; once when made by Michael Cemovich; and a third time when made by the Miami Herald), and because these issues are currently on appeal in the Second Circuit, Mr. Dershowitz asks that
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
partially redacted, and the order denying the motion to unseal was itself sealed. The second individual, podcast host and investigative journalist Michael Cemovich, moved to intervene and unseal Defendant's Motion for Summary Judgment (the "Cemovich Motion"). (ECF No. 550.) The portion of the Cemovich motion se
, Denver, CO 80203, By: Laura A. Menninger, Esq., Jeffrey S. Pagliuca, Esq., Ty Gee, Esq. Counsel for Int
Page: EFTA00020552 →OREMAN, P.C., 150 East 10th Avenue, Denver, CO 80203, By: Laura A. Menninger, Esq., Jeffrey S. Pagliuca, Esq., Ty Gee, Esq. Counsel for Intervenor Michael Cemovich: RANDAZZA LEGAL GROUP, PLLC, 100 Pearl Street, 14th Floor, Hartford, CT 06103, By: Jay M. Wolman, Esq. Counsel for Intervenor Alan Dershowitz: EMER
Page: EFTA00020552 →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
Page: EFTA00020554 →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
Page: EFTA00020554 →the 11th day of September, two thousand twenty. Plaintiff:Appellee, ORDER v. 20-2413 Ghislaine Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Media, Intervenors. It is hereby ORDER
Page: EFTA00028060 →, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media C
Page: EFTA00028060 →Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald
Page: EFTA00028060 →slaine Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Media, Intervenors. It is hereby ORDERED that the United States shall submit an amicus letter brief, not to exceed ten (10) double-s
Page: EFTA00028060 →, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media C
Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald
the 11th day of September, two thousand twenty. Plaintiff-Appellee, ORDER v. 20-2413 Ghislaine Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Media, Intervenors. It is hereby ORDER
slaine Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Media, Intervenors. It is hereby ORDERED that the United States shall submit an amicus letter brief, not to exceed ten (10) double-s
the 11th day of September, two thousand twenty. Plaintiff-Appellee, ORDER v. 20-2413 Ghislaine Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Media, Intervenors. It is hereby ORDER
, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media C
Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald
slaine Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Media, Intervenors. It is hereby ORDERED that the United States shall submit an amicus letter brief, not to exceed ten (10) double-s
, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media C
Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald
the 11th day of September, two thousand twenty. Plaintiff-Appellee, ORDER v. 20-2413 Ghislaine Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Media, Intervenors. It is hereby ORDER
slaine Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Media, Intervenors. It is hereby ORDERED that the United States shall submit an amicus letter brief, not to exceed ten (10) double-s
t Ghislaine Maxwell, alleging that Maxwell had defamed by stating that was not the victim of sex crimes perpetrated by, among others, Maxwell and Jeffrey Epstein ("Epstein"). (15-cv- 7433, Dkt. No. I.) Boies Schiller represented the plaintiff in the litigation, and continues to represent her on a pending post
ll, alleging that Maxwell had defamed by stating that was not the victim of sex crimes perpetrated by, among others, Maxwell and Jeffrey Epstein ("Epstein"). (15-cv- 7433, Dkt. No. I.) Boies Schiller represented the plaintiff in the litigation, and continues to represent her on a pending post-settlemen
the allegations against Epstein and suggesting that the plea deal constituted Government misconduct. Liam Stack, US. Opens Inquiry Into Handling of Jeffrey? Epstein's Sex Abuse Case, N.Y. Times (Feb. 6, 2019), https://www.nytimes.com/2019/02/06/usfibi-jeffrey-epstein.html. The expose garnered attention
ein, moved to unseal a limited portion of the record in order to clear his name. (15-cv-7433, Dkt. No. 364 at 1.) Alt-right activist and provocateur Michael Cemovich also sought to unseal the papers filed as part of Maxwell's motion for summary judgment, arguing, "Cemovich Media cannot conduct its Forth [sic] Es
Entities connected to both Jeffrey Epstein and Michael Cemovich

Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Woody Allen
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
Julie K. Brown
PERSON
Virginia Giuffre
PERSON
David Boies
PERSON
Southern District of New York
ORGANIZATION
Larry Page
PERSONSecond Circuit
ORGANIZATION
Cynthia Nixon
PERSON
Nassau
LOCATION
Foley Square
LOCATIONSweet
PERSON
Bernstein
PERSON
Schiller
PERSONthe City of New York
LOCATIONLoretta A. Preska
PERSONSharon Churcher
PERSON