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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
1, 14 United States v. Erie Cniy., 763 F.3d 235 (2d Cir. 2014) 14 United States v. Samar, 471 F. Supp. 2d 380 (S.D.N.Y. 2006) 11 Wilson v. Am. Motors Corp., 759 F.2d 1568 (11th Cir. 1985) 8 OTHER AUTHORITIES Fed. R. Civ. P. 24 1, 7 iii EFTA00805410 Case 1:15-cv-07433-RWS Document 936 Filed 04/06
736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. ORDER REQUESTING JUSTIFICATION FOR INTERVENOR EPSTEIN'S UNOPPOSED MOTION FOR A SUPPLEMENTAL PROTECTIVE ORDER This cause is before the Court on Intervenor Jeffrey Epstein's Unopposed Motion for a Suppl
REQUESTING JUSTIFICATION FOR INTERVENOR EPSTEIN'S UNOPPOSED MOTION FOR A SUPPLEMENTAL PROTECTIVE ORDER This cause is before the Court on Intervenor Jeffrey Epstein's Unopposed Motion for a Supplemental Protective Order. (DE 261). Without opposition from either Petitioners (Plaintiffs) or Respondent (Defendant),
DER This cause is before the Court on Intervenor Jeffrey Epstein's Unopposed Motion for a Supplemental Pr
60 F.2d 1013, 1016 (11th Cir. 1992). Wilson I. EFTA00210756 Case 9:08-cv-80736-KAM Document 286 Entered on FLSD Docket 01/14/2015 Page 2 of 2 Am. Motors Corp., 759 F.2d 1568, 1570 (11th Cir. 1985). DONE AND ORDERED in chambers at West Palm Beach, Palm Beach County, Florida, this 14ih day of January, 2015.
736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. ORDER REQUESTING JUSTIFICATION FOR INTERVENOR EPSTEIN'S UNOPPOSED MOTION FOR A SUPPLEMENTAL PROTECTIVE ORDER This cause is before the Court on Intervenor Jeffrey Epstein's Unopposed Motion for a Suppl
REQUESTING JUSTIFICATION FOR INTERVENOR EPSTEIN'S UNOPPOSED MOTION FOR A SUPPLEMENTAL PROTECTIVE ORDER This cause is before the Court on Intervenor Jeffrey Epstein's Unopposed Motion for a Supplemental Protective Order. (DE 261). Without opposition from either Petitioners (Plaintiffs) or Respondent (Defendant),
DER This cause is before the Court on Intervenor Jeffrey Epstein's Unopposed Motion for a Supplemental Pr
60 F.2d 1013, 1016 (11th Cir. 1992)• Wilson v. EFTA00607363 Case 9:08-cv-80736-KAM Document 286 Entered on FLSD Docket 01/14/2015 Page 2 of 2 Am. Motors Corp., 759 F.2d 1568, 1570 (11th Cir. 1985). DONE AND ORDERED in chambers at West Palm Beach, Palm Beach County, Florida, this 14ih day of January, 2015.
, which has been consolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when
nsolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when the girls
-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 0
352, 356 (11th Cir. 1987). The burden is on the party seeking the protective order to demonstrate good cause for its issuance. See Phillips v. Gen. Motors Corp. 307 F.3d 1206, 1210-11 (9th Cir. 2002); In re Agent Orange Products Liability Litigation, 821 F.2d 139, 145 (2d Cir. 1987); 19th Street Baptist Chu
, which has been consolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when
nsolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when the girls
-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 0
352, 356 (11th Cir. 1987). The burden is on the party seeking the protective order to demonstrate good cause for its issuance. See Phillips v. Gen. Motors Corp. 307 F.3d 1206, 1210-11 (9th Cir. 2002); In re /went Orange Products Liability Litigation, 821 F.2d 139, 145 (2d Cir. 1987); 19th Street Baptist Chu
Entities connected to both Jeffrey Epstein and Motors Corp.

Sarah Kellen
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Julie K. Brown
PERSON
Scarlett Johansson
PERSONChambers
PERSONJANE DOE NO
PERSONFLSD Docket
ORGANIZATIONPhillips
PERSONAndriano
PERSONAlexander Grant & Co. Litigation
ORGANIZATIONR. JO
PERSONE.D. Penn
ORGANIZATIONFirst Am
ORGANIZATIONHosp.. Inc.
ORGANIZATIONSt. Peters Episcopal Church
ORGANIZATIONpp.5-6
LOCATIONOrange Products Liability Litigation
ORGANIZATION19th Street Baptist Church
ORGANIZATIONF.R.D. 345
ORGANIZATION