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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
utyl Ether (MTBE) Prods. Liab. Litig., MDL No. 1358, 2013 WL 3531600 (S.D.N.Y. July 12, 2013) 10 In re NASDAQ Market-Makers Antitrust Litig., 164 F.R.D. 346 (S.D.N.Y. 1996) 7 ii EFTA00805409 Case 1:15-cv-07433-RWS Document 936 Filed 04/06/18 Page 4 of 21 In re Onusicom Grp., Inc. Sec. Litig., No. 0
he allegations against Epstein and suggesting that the plea deal constituted Government misconduct. Liam Stack, U.S. Opens Inquiry Into Handling of Jeffrey Epstein's Sex Abuse Case, N.Y. Times (Feb. 6, 2019), https://www.nytimes.com/2019/02/06/usgbi-jeffrey-epstein.html. The exposi garnered attention from the med
hat Maxwell had defamed Giuffre by stating that Giuffre was not the victim of sex crimes perpetrated by, among others, Maxwell and Jeffrey Epstein ("Epstein"). (15-cv- 7433, Dkt. No. 1.) Boies Schiller represented the plaintiff in the litigation, and continues to represent her on a pending post-settlemen
crimes perpetrated by, among others, Maxwell and Jeffrey Epstein ("Epstein"). (15-cv- 7433, Dkt. No. 1.) B
onable, where a protective order is, as here, a blanket order entered by stipulation of the parties." In re NASDAQ Mkt.-Makers Antitrust Litig., 164 F.R.D. 346, 356 (S.D.N.Y. 1996). As for the last factor, the nature of the parties' reliance on the order does seem to weigh against modification. "The classi
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
onable, where a protective order is, as here, a blanket order entered by stipulation of the parties." In re NASDAQ Mkt.-Makers Antitrust Litig., 164 F.R.D. 346, 356 (S.D.N.Y. 1996). As for the last factor, the nature of the parties' reliance on the order does seem to weigh against modification. "The classi
Entities connected to both Jeffrey Epstein and F.R.D. 346

Ghislaine Maxwell
PERSON
Woody Allen
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
United States
LOCATION
Julie K. Brown
PERSONthe Southern District
LOCATION
Virginia Giuffre
PERSON
David Boies
PERSON
Southern District of New York
ORGANIZATIONSecond Circuit
ORGANIZATION
Nassau
LOCATIONColleen McMahon
PERSON
Orange
LOCATION
Schiller
PERSONCircuit Court
ORGANIZATIONMartindell
PERSONthe Bankruptcy Court
ORGANIZATIONN.Y. Post
ORGANIZATIONOnondaga
LOCATION