Epstein Secrets

xwell's failure is especially jarring in light of the public's interest in this litigation, which involved voluminous documents and testimony about Jeffrey Epstein's transcontinental sex-trafficking operation and documents concerning various public agencies' utter failure to protect and bring justice to his vict

ed, a quick 6 EFTA00075033 CasqaMglitg6taagtalmeabgineAFIVA04146legiteaMbbef-138f 24 Google search of Doe 1 or Doe 2's last name, plus the term "Epstein" or "Maxwell," reveals much of the information about those Non-Parties that is currently under seal. The only argument that Maxwell makes concernin

nvolved voluminous documents and testimony about Jeffrey Epstein's transcontinental sex-trafficking operat

investigation "surrounding the alleged conduct of Mr. Epstein," provides no other information, yet states in a

ause only Doe 1 and Doe 2 have received notice of potential sealing thus far, and because the first five motions contain the names of various other Non-Parties, Maxwell contends in her objection that the Court cannot unseal any of the first five motions or their related docket entries until each Non-Party

v. Indyke, Case No. 19-cv-10475-LGS See, e.g., wants Ghislaine Maxwell to `rot in jail," NY Post (Dec. 4, 2019); Andrew Denney and Bruce Golding, "Jeffrey Epstein's no-bail ruling may encourage more accusers to come forward," NY Post (July 18, 2019) ("McCawley wouldn't identify her new clients but said she enco

ted pleadings involve Plaintiff's effort which were not and should not have been relevant to Plaintiffs false claim that she was sexually abused by Epstein as a minor. The Second Circuit in Brown itself redacted from the summary judgment pleadings and exhibits all of Ms. Maxwell's deposition answers in

o tnsealinu Sealed Materials Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN,

l the questions, lawsuit filed a lawsuit against Mr. Epstein to produce In fact, in connection with her cur

f the judicial function," "not considered a judicial document" and enjoys "no presumption of public access."). Further, in addition to Doe 1, other Non-Parties are included in DE's 185-3, 185-11, 185- 14 and 185-15 each of whom has not yet been notified or had the opportunity to object under this Court's Pr

44, 08/20/2020, 2913556, Pagel of 78 20-2413 United States Court of Appeals for the Second Circuit —against— GHISLAINE MAXWELL, SHARON CHURCHER, JEFFREY EPSTEIN, PlaintiffiAppellee, Defendant-Appellant, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNO

3, Document 44. 08/20/2020, 2913556, Page42 of 78 App.-0816 12 G4LMGIUC 1 four individuals had sexually abused her prior to ever meeting 2 Mr. Epstein. 3 If she has evidence that she already was suffering 4 from depression or some type of mental health disorder before 5 meeting our client, Ms.

t —against— GHISLAINE MAXWELL, SHARON CHURCHER, JEFFREY EPSTEIN, PlaintiffiAppellee, Defendant-Appellan

had sexually abused her prior to ever meeting 2 Mr. Epstein. 3 If she has evidence that she already was suf

week per Non-Party to agree to the excerpts to send to them for review. But on balance we agree that having a sense of the number of participating Non-Parties will aid the Court in conducting future proceedings, we have agreed to Plaintiff's suggestion on that front. The parties can submit a proposed modif

the Southern District of New York, and the Attorney General for the U.S. Virgin Islands, that investigations surrounding the alleged conduct of Mr. Epstein survive his death. It is unclear who are witnesses or targets of any investigation. These ongoing investigations are a powerful countervailing inter

es 164 and 230 at This Time. Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN,

e. The absence of a response, however, does not end the analysis. Although the Court's Protocol requires consideration of objections from the other Non-Parties yet to be noticed, the Court could (and should) determine, based on the circumstances of the Sealed Materials selected here, that the items are appr

to place Plaintiff's submission into context. DE 153 is Plaintiff's reply which, again quotes from Ms. Maxwell's deposition and references numerous Non-Parties. DE 153-1 contains 7 exhibits. Exhibit I is a portion of Ms. Maxwell's deposition. Exhibit 2 contains a "Flight Log Summary Chart" prepared by Plain