Epstein Secrets

likely relevant to its pending Virgin Islands Criminally Influenced and Corrupt Organizations Act ("CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities before the Superior Court of the U.S. Virgin Islands. See Exhibit A hereto (USVI's operative First Amended C

Virgin Islands Criminally Influenced and Corrupt Organizations Act ("CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities before the Superior Court of the U.S. Virgin Islands. See Exhibit A hereto (USVI's operative First Amended Complaint, filed Feb

"CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities

"CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities b

l sought by the public or press, the material `should not remain under seal absent the most compelling reasons.'" Lugosch, 435 F.3d at 123 (quoting Joy v. North, 692 F.2d 880 (2d Cir. 1982)); Guzik v. Albright, No. 16-CV-2257 (JPO), 2018 U.S. Dist. LEXIS 196006, at *6-7 (S.D.N.Y. Nov. 16, 2018) (noting neit

likely relevant to its pending Virgin Islands Criminally Influenced and Corrupt Organizations Act ("CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities before the Superior Court of the U.S. Virgin Islands. See Exhibit A hereto (USVI's operative First Amended C

Virgin Islands Criminally Influenced and Corrupt Organizations Act ("CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities before the Superior Court of the U.S. Virgin Islands. See Exhibit A hereto (USVI's operative First Amended Complaint, filed Feb

"CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities

"CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities b

l sought by the public or press, the material `should not remain under seal absent the most compelling reasons.'" Lugosch, 435 F.3d at 123 (quoting Joy v. North, 692 F.2d 880 (2d Cir. 1982)); Guzik v. Albright, No. 16-CV-2257 (JPO), 2018 U.S. Dist. LEXIS 196006, at *6-7 (S.D.N.Y. Nov. 16, 2018) (noting neit

f the media and claims to have looked at the journal to "refresh [her] memory about this time." See, e.g., Michael Baker, "The First Women to Report Jeffrey Epstein," The Daily Podcast, NY Times (Aug. 26, 2019), Tr. at 2 ("When I was looking, trying to refresh my memory about this time, I came across this journa

vers, were selectively produced by BSF in discovery during civil litigation to counsel for Ms. Maxwell, apparently as support for her claims against Epstein. The civil litigation was stayed and ultimately dismissed prior to resolution of questions related to the failure to produce the entire journal. Ac

York, NY 10007 Haddon, Morgan and Foreman. t.c Jeffrey PaglIuca 150 East 10th Avenue Denver. Colorado

ly misleading evidence." In re von Bulow, 828 F.2d 94, 102 (2d Cir. 1987); see also United States v. Bilzerian, 926 F.2d 1285, 1292 (2d Cir. 1991); Joy v. North, 692 F.2d 880, 893-94 (2d Cir. 1982); Teachers Ins. & Annuity Assin of America v. Shamrock Broadcasting Co., 521 F.Supp. 638 (S.D.N.Y. 1981). 2 As

2 of 27 IN THE UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT Plaintiff-Appellee, v. GHISLAINE MAXWELL, Defendant, v. SHARON CHURCHER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, Intervenors-Appellants No. 18-2868 Appellee Maxwell's Motion to Reconsider and Vacate th

AXWELL, Defendant, v. SHARON CHURCHER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD MEDIA

SLAINE MAXWELL, Defendant, v. SHARON CHURCHER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD

serve that interest.' ") (quoting Press-Enter. Co. a Superior Court of Cal. for Riverside Cny., 478 U.S. 1, 9 (1986); internal quotations altered); Joy v. North, 692 F.2d 880, 893 (2d Cir. 1982) (cited with approval in Lugosch and applying presumption of access to summary judgment 14 EFTA00791883 Case 18