Epstein Secrets

ow precise. complete statement of relief sought: Order to Show Cause and March 13 Order should be reconsidered and vacated MOVING PARTY: Defendant Ghislaine Maxwell OPhintiff DDefendant ['Appellant/Petitioner nAppeUee/Respondent MOVING ATTORNEY: Ty Gee [name of attorney, with fm. Haddon, Morgan and Foreman

Case 18-2868, Document 141, 03/15/2019, 2519388, Page2 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-

ment 141, 03/15/2019, 2519388, Page4 of 27 has the ability to balance the public's interest in access to the discovery in court filings against Ms. Maxwell's and the non-parties' compelling interests. This is an extraordinary case. Ms. for more than a decade has actively pursued publicity and money fo

access to the discovery in court filings against Ms. Maxwell's and the non-parties' compelling interests. Thi

the protections afforded the parties and non-parties under this Court's right-to-access jurisprudence. The appellants Miami Herald, Dershowitz and Cernovich —and the Court in its Order to Show Cause—rested heavily on Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). With respect, neither

April 2017 he stipulated to dismissal of his appeal without prejudice. In July 2017 he moved to reinstate his appeal and to consolidate it with Mr. Cernovich's appeal. Merits briefing concluded by early 2018. Supplemental briefing was concluded by April 2018. Discussion None of the appellants is entitle

of girls at his Palm Beach mansion. Two women — one of whom was underage — have said Epstein and his partner, British socialite and environmentalist Ghislaine Maxwell, directed them to have sex. with Dershowitz, 80, and other wealthy, powerful men. Dershowitz and Maxwell have denied the claims. Oral arguments are

ish socialite and environmentalist Ghislaine Maxwell, directed them to have sex. with Dershowitz, 80, and other wealthy, powerful men. Dershowitz and Maxwell have denied the claims. Oral arguments are scheduled Wednesday to hear an appeal by the Miami Herald and other parties seeking to unseal a 2015 cour

s partner, British socialite and environmentalist Ghislaine Maxwell, directed them to have sex. with Dershowi

ed the law because he and other prosecutors deliberately kept the deal secret from Epstein’s vic- tims, who are now in their late 20s and early 30s. Cernovich’s lawyer, Marc J. Randazza, said he has never seen a court seal nearly an entire court record like this. “T've seen partial seals, but I’ve never se

Brown v. Maxwell, — F.3d — (2019) 2019 WL 2814839 Only the Westlaw citation is currently available. United States Court of Appeals, Second Circuit. Julie BROWN,

citation is currently available. United States Court of Appeals, Second Circuit. Julie BROWN, Miami Herald Company, Intervenors-Appellants, v. Ghislaine MAXWELL, Defendant-Appellee, v. MM. Plaintiff-Appellee. . r owitz, Michael Cernovich, dba Cernovich Media, Intervenors-Appellants, v. Plaintiff-App

ating accusations. In response to the allegations, on January 3, 2015, Maxwell's publiSid a press statement declaring that allegations "against Ghislaine Maxwell are untrue" and that her "claims are obvious lies."6 6 SeMIEv. Maxwell, 325 F. Supp. 3d 428, 434 (S.D.N.Y. 2018). BM Sues Maxwell On

moved to intervene, seeking to unseal three do l. that, he argues, demonstrate that invented the accusations against him. On January 19, 2017, Cernovich, an independent blogger and self-described "popular political journalist,"7 moved to intervene, seeking to unseal the summary judgment record, a

18-2868; 16-3945-cv(L) Brown v. Maxwell; Dershotvitz v. Giuffre 3n tlje Elute)) i§tateo Court of appeat55 for the i§ecortb Circuit AUGUST TERM 2018 No. 18-2868-cv JULIE BROWN, MIAMI H

tateo Court of appeat55 for the i§ecortb Circuit AUGUST TERM 2018 No. 18-2868-cv JULIE BROWN, MIAMI HERALD COMPANY, Intervenors-Appellants, v. GHISLAINE MAXWELL, Defendant-Appellee, v. VIRGINIA L. GIUFFRE, Plaintiff-Appellee. No. 16-3945-cv(L) No. 17-1625 (CON) No. 17-1722(CON) ALAN M. DERSHOW

ons. In response to the allegations, on January 3, 2015, Maxwell's publicist issued a press statement declaring that Giuffre's allegations "against Ghislaine Maxwell are untrue" and that her "claims are obvious lies. "6 B. Giuffre Sues Maxwell On September 21, 2015, Giuffre filed the underlying action against

d, and Dershowitz joined his motion. On April 6, 2018, after the case had settled, the Herald moved to intervene and unseal , an' 7 Br. Appellant (Cernovich) 4. 8 EFTA00092315 the entire docket. The District Court granted each of these motions to intervene, but denied the related requests to unseal i

v. Maxwell, — F.Supp.3d — (2018) 2018 WL 4062649 Only the Westlaw citation is currently available. United States District Court, S.D. New York. Plaintiff,

F.Supp.3d — (2018) 2018 WL 4062649 Only the Westlaw citation is currently available. United States District Court, S.D. New York. Plaintiff, v. Ghislaine MAXWELL, Defendant. 15 Civ. 7433 i Signed 08/27/2018 Synopsis Background: Following settlement of plaintiff's action for defamation, news media and inv

s District Court, S.D. New York. Plaintiff, v. Ghislaine MAXWELL, Defendant. 15 Civ. 7433 i Signed 08/2

her claim of defamation by Maxwell arising out of the Maxwell January 3 Statement. alleged she was the "victim

Granting Dershowitz Motion to Intervene); v. Maxwell, No. 15 Civ. 7433 (RWS), 2017 WL 1787934 (S.D.N.Y. May 3, 2017), ECF No. 892 (Opinion Granting Cernovich Motion to Intervene). 121 PIAlthough the case was closed by the Clerk of Court on May 25, 2017 pursuant to the settlement agreement, "intervention