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uly 10.2020.2:06 AN1 • I I mm mod GNsialne Maxwell behind ban as new details emerge Jeffrey Epstein's ex-gw1.0. Wenta. groom and 11 VI • J.66, Epstem's sex aunts by he@ng him Ghislaine Maxwell, a British socialite and longtime companion of disgraced financier Jeffrey Epstein, is facing a reckonin
ficant facts since briefing closed on the first round of review of sealed materials. After many months of relentless negative media coverage of Mr. Epstein and allegations that Ms. Maxwell was involved in his criminal activities, the government secured an indictment against her. On July 2, one day after
his apartments in New York City — near his own townhouse, where he would allegedly rape her the next year. MAIM Feds finally start investigating Jeffrey Epstein's gal pal Ghislaine Maxwell "In 1997, while at Epstein's townhouse on 9 East 71st Street in the City of New York. Epstein asked 17-year-old Doe if sh
TA00075089 ca3FtsVrit5164 Get. PtiftitPtiktivektA8Siig W*40441319 Q. List all the people under the age of 18 that you interacted with at any of Jeffrey's properties? A. I'm not aware of anybody that I interacted with, other than obviously (the plaintiff) who was 17 at this point. (Title 18, Unit
months of relentless negative media coverage of Mr. Epstein and allegations that Ms. Maxwell was involved in
l notice, as Judge Nathan herself may have, of the widespread negative media publicity and speculation directed at Mr. Epstein and Ms. Maxwell. See Condit v. Dunne, 317 F. Supp. 2d 344, 358 (S.D.N.Y. 2004). We attach a compilation of such articles in EXHIBIT E. The Court also may take judicial notice of Ms. Ma
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
. Fishbein, 227 F.R.D. 239, 254 (S.D.N.Y. 2005) (movant must demonstrate good cause for order barring public dissemination of discovery materials); Condit v. Dunne, 225 F.R.D. 113, 115 (S.D.N.Y. 2004) (same). To show good cause under Rule 26(c), parties must demonstrate that disclosure will cause a clear and
ficant facts since briefing closed on the first round of review of sealed materials. After many months of relentless negative media coverage of Mr. Epstein and allegations that Ms. Maxwell was involved in his criminal activities, the government secured an indictment against her. On July 2, one day after
months of relentless negative media coverage of Mr. Epstein and allegations that Ms. Maxwell was involved in
l notice, as Judge Nathan herself may have, of the widespread negative media publicity and speculation directed at Mr. Epstein and Ms. Maxwell. See Condit v. Dunne, 317 F. Supp. 2d 344, 358 (S.D.N.Y. 2004). We attach a compilation of such articles in EXHIBIT E. The Court also may take judicial notice of Ms. Ma
Entities connected to both Jeffrey Epstein and Condit v. Dunne

Ghislaine Maxwell
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Julie K. Brown
PERSON
Virginia Giuffre
PERSON
Bradley Cooper
PERSON
Harvey Weinstein
PERSON
David Boies
PERSON
Denver
LOCATION
Colorado
LOCATION
Southern District of New York
ORGANIZATION
Audrey Strauss
PERSONSigrid McCawley
PERSON
The New York Times
ORGANIZATION
Cynthia Nixon
PERSON
Foreman
PERSONHaddon
PERSONSweet
PERSON
Boies Schiller
ORGANIZATION