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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
conclusory statements." Havens v. Metropolitan Life Insurance Co., No. 94 CIV. 1402 (CSH), 1995 WL 234710, at *10 (S.D.N.Y. April 20, 1995) (quoting Cipollone v. Liggett Grp., Inc., 785 F.2d 1108, 1121 (3d Cir. 1986)); see also Carlson v. Geneva City Sch. Dist., 277 F.R.D. 90, 94 (W.D.N.Y. 2011) (requirin
man a Audre Strauss EFTA00047124 As discussed, we would like to see the 2n° floor pscyh observation and suicide watch area; the r floor SHU, and Epstein's cell, which we understand to still be cordoned off. As discussed, we would appreciate if only MCC legal would escort us, and we will not speak to
only will England's Prince Andrew stand aside from all of his 230 patronages after a scandalous interview about his relationship with sex offender Jeffrey Epstein, he also won't be able to throw a birthday bash next year, under orders from the Queen. From the Guardian: "The blanket move represents a key step
terview about his relationship with sex offender Jeffrey Epstein, he also won't be able to throw a birthd
l ... "The document research has only exacerbated growing tension between [White House Counsel Pat] Cipollone and Mulvaney and their offices, with Cipollone tightly controlling access to his findings, and Mulvaney's aides complaining Cipollone isn't briefing other White House officials or sharing import
only will England's Prince Andrew stand aside from all of his 230 patronages after a scandalous interview about his relationship with sex offender Jeffrey Epstein, he also won't be able to throw a birthday bash next year, under orders from the Queen. From the Guardian: "The blanket move represents a key step
e blanket move represents a key step in Buckingham Palace's attempts to limit the damage to the British monarchy from the prince's association with Epstein and his interview with BBC Two's Newsnight last EFTA00047180 weekend in which he was widely thought to have shown insufficient concern for Epstei
terview about his relationship with sex offender Jeffrey Epstein, he also won't be able to throw a birthda
al ... "The document research has only exacerbated growing tension between [White House Counsel Pat] Cipollone and Mulvaney and their offices, with Cipollone tightly controlling access to his findings, and Mulvaney's aides complaining Cipollone isn't briefing other White House officials or sharing import
Entities connected to both Jeffrey Epstein and Cipollone

Prince Andrew
PERSON
John F. Kennedy
PERSON
George Mitchell
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Lawrence Krauss
PERSON
Joe Biden
PERSON
Prince Charles
PERSON
Julie K. Brown
PERSON
Bill Clinton
PERSONthe Southern District
LOCATION
Virginia Giuffre
PERSONEmmy Taylor
PERSON
Michael Jackson
PERSON
Bloomberg L.P.
ORGANIZATION
Paul Ryan
PERSON
Barack Obama
PERSON
Bernie Sanders
PERSON
Hillary Clinton
PERSON
San Diego
LOCATION