Epstein Secrets

Cagean.g0c44/ 71SEAFierbd664164i igl5V2PilaW6M/Joagria44 1?)f 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Objections to Unsealing Docket Entries 143. 173. and 199 and to Unsealing Docket Entries 164

ia44 1?)f 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Objections to Unsealing Docket Entries 143. 173. and 199 and to Unsealing Docket Entries 164 and 230 at This Time. Laura A. Menninger Jeffrey S.

RGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 EFTA00075004 CageaUlg0caAIDer0dthhilfii igl5V2Pil&iA6/2bagctacir4 2%f 3 Defendant Ghislaine Maxwell, through her counsel and pursuant to this Court's Order and Protocol for Unsealing Decided Motions, DE 1044, as clarified by DE 1053, objects to the

supporting continued sealing/redaction of the item, and (c) whether the countervailing interests rebut the presumption of public access to the item. n. Maxwell, No. 15-CV-07433-LAP, 2020 WL 1547377, at *1 (S.D.N.Y. Mar. 31, 2020); DE 1044.' Based on the Court's clarification of its March 31, 2020 Order, DE

ISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Objections to Unsealing Docket Entries 143. 173

involved in an investigation"; "[title district court was in the best position to weigh these factors") (internal quotations and citation omitted); Hardy, 697 Fed. App'x at 725 (2d Cir. 2017) (noting that courts have found that the following can defeat presumption of access: protection of ongoing inv

ase 1:15-cv-07433-RWS Document 936 Filed 04/06/18 Page 1 of 21 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, - against - GHISLA1NE MAXWELL, Defendant. : Case No. 15-cv-7433 (RWS) MEMORANDUM OF LAW IN SUPPORT OF PROPOSED INTERVENORS JULIE BROWN AND MIAMI HERALD MEDIA COMPANY'S MOTIO

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 ARGUMENT 6 I. MIAM

ABLE 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 ARGUMENT 6 I. MIAMI HERALD

. " or "Plaintiff') against Ghislaine Maxwell ("Ms. Maxwell" or "Defendant") on the grounds that Ms. Maxwell,

nesses, endanger national security, reveal trade secrets, or implicate duty to protect attorney-client material or confidential client information); Hardy, 2017 WL 6805707, at *6-7 (unsealing transcript of settlement between workers' union and, inter alia, the Trump Organization and holding that, unde

HE NEWS • Federal Prosecutors Release Details Of Ghislaine Maxwell's Arrest. PROTESTS • Trump Criticizes "

HE NEWS • Federal Prosecutors Release Details Of Ghislaine Maxwell's Arrest. PROTESTS • Trump Criticizes "Anti-Cop C

desk, a seemingly misguided effort to evade detection from law enforcement. Prosecutors in a new court filing today asking a federal judge to keep Maxwell, the former girlfriend and alleged co- conspirator of convicted sex offender Jeffrey Epstein, behind bars." CNN (7/13, Scannell, 83.16M) reports, "F

as refused to declare her financial situation and they have been unable to determine whether she has had a job in more than 30 years. They rejected Ms Maxwell's $5 million bail proposal, claiming that offering a $3.75m home in London as collateral was meaningless as it could not be seized by US authorities.

rces in identifying the estimated sale price." FBI Continues Probe Of Independence, Missouri Government. The Kansas City (MO) Star (7/13, Hancock, Hardy, Vockrodt, 549K) reports, "The FBI has once again requested records from Independence City Hall, the latest in a series of inquiries by federal aut

K UNITED STATES OF AMERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S OMNIBUS MEMORANDUM

K UNITED STATES OF AMERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S OMNIBUS ME

exual abuse but not a necessary consequence of sexual abuse, jurors have no means to determine whether a Minor Victim is lying or telling the truth GM 7 The defendant also argues that Dr. is not an expert in "the human brain or memory generally." (Def. Mot. 3 at 17). The overnment agrees. But Dr.

m-3's allegations "may reflect conduct 43 EFTA00088845 undertaken in furtherance of the charged conspiracy or be relevant to prove facts such as Maxwell's state of mind." (id. at 26-27). B. Applicable Law It is axiomatic that the Government may offer proof of acts included within the indictment. Th

f identification" by showing a person in that position even a single photograph, much less a photo array or photo book. See, e.g., United States v. Hardy, No. 10 Cr. 1123 (JSR), 2011 WL 7782582 (S.D.N.Y. Jan. 25, 2011) ("Displaying a confirmatory photograph of a person the witness has indicated that

43R-ficsarnecobalrgefiFiW044136§fgheatmbefilth 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-RWS INTERVENORS' JULIE BROWN AND MIAMI HERALD MEDIA CO.'S RESPONSE TO MAXWELL'S OBJECTIONS TO UNSEALING Sanfor

F NEW YORK Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-RWS

rotocol for Unsealing Decided Motions, Intervenors Julie Brown and Miami Herald Media Co. ("Miami Herald") respectfully submit this response to Ms. Maxwell's Memorandum Brief in Support of Her Objections to Unsealing Sealed Materials (Dkt. 1057) ("the Objections")} ARGUMENT Ms. Maxwell's objections to

mi Herald") respectfully submit this response to Ms. Maxwell's Memorandum Brief in Support of Her Objections t

judicial documents and that reflected sensitive information about cooperating witnesses and the government's investigative methods and techniques); Hardy v. Equitable Life Assurance Soc'y of United States, 697 F. App'x 723, 725 (2d Cir. 2017) (noting generally that protection of ongoing investigation

erbdthhiEgti id5i352PiletiViMdbagriad4 1?)f 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP \ Is. Maxwell's Objections to Unsealing Docket Entries 143, 173, and 199 and to Unsealing Docket Entries 164 and 2

TES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP \ Is. Maxwell's Objections to Unsealing Docket Entries 143, 173, and 199 and to Unsealing Docket Entries 164 and 230 at This Time. Laura A. Menninger Jeffrey S.

filegi i15§392PilgRiA6/2bagrt&j4 2%f 3 Defendant Ghislaine Maxwell, through her counsel and pursuant to this

re stated in her accompanying memorandum of law. Ms. Maxwell, does not object to the potential unsealing of th

involved in an investigation"; "[t]tle district court was in the best position to weigh these factors") (internal quotations and citation omitted); Hardy, 697 Fed. App'x at 725 (2d Cir. 2017) (noting that courts have found that the following can defeat presumption of access: protection of ongoing inv