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

he integrity of criminal investigations and the privacy and safety of witnesses and suspects that are part of those investigations. United States v. Longueuil, 567 F. App'x 13, 16 (2d Cir. 2014) (holding that district court properly sealed contested documents "as they reflected sensitive information about

nver, Colorado 80203 PH 303.831.7364 HI 303.832.2628 www.hmtlaw.com [email protected] Re: Reconsideration of the Court's July 23 Ruling Giuffie v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its Protective Order and punish

.com Re: Reconsideration of the Court's July 23 Ruling Giuffie v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its Protective Order and punish its violation. Ms. Maxwell's two deposition transcripts were designated

eration of the Court's July 23 Ruling Giuffie v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Presk

v. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its

ining the Maxwell materials from Boies Schiller, the Maxwell Protective Order explicitly provides that (1) di

fairness to the defendants, see W. at 602 n.14. In In re New York Times Co., 828 F.2d 110 (2d Cir. 1987), cited with approval in United States v. Longueuil, 567 Fed. App'x 13,16 (2d Cir. 2014), Judge Weinstein denied the media's motion to unseal papers filed in connection with an unsuccessful defense mo

MAXWELL JEFFREY EPSTEIN, PRINCE ANDREW, 3/22/20 EFTA00075107 Casgastetal14331atitilmetbdOnttit7187.82412CF 057g9/28gEFEeigef 6208161 Socialite Ghislaine Maxwell 'groped a 16-year-old girl during a naked massage,' victims' lawyer says El dailvmail.co.ukThews/article-8163681/Socialite-Ghislaine-Maxwell-qroped-1

.com Re: Reconsideration of the Court's July 23 Ruling Giuffie v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its Protective Order and punish its violation. Ms. Maxwell's two deposition transcripts were designated

rated for Jeffrey Epstein's personal sexual satisfaction. So to the degree that um there was a main facilitator that started the whole thing, it was Ghislaine. 3 A purported transcript of the press conference is contained on the intemet at https://www.rev.comiblog,/transcripts/announcement-transcript-of-c

v. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its

ining the Maxwell materials from Boies Schiller, the Maxwell Protective Order explicitly provides that (1) di

fairness to the defendants, see id. at 602 n.14. In In re New York Times Co., 828 F.2d 110 (2d Cir. 1987), cited with approval in United States v. Longueuil, 567 Fed. App'x 13, 16 (2d Cir. 2014), Judge Weinstein denied the media's motion to unseal papers filed in connection with an unsuccessful defense m

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

her interests can rise to the level of a compelling interest sufficient to overcome any presumption of right to access. See, e.g., United States v. Longueuil, 567 F. App'x 13, 16 (2d Cir. 2014) (holding that district court properly sealed contested documents "as they reflected sensitive information about

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ver, Colorado 80203 ni 303.831.7364 rx 303.832.2628 www.hmtlaw.com tgeefghmflaw.com Re: Reconsideration of the Court's July 23 Ruling Giuffre v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its Protective Order and punish

.com Re: Reconsideration of the Court's July 23 Ruling Giuffre v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its Protective Order and punish its violation. Ms. Maxwell's two deposition transcripts were designated

eration of the Court's July 23 Ruling Giuffre v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Presk

v. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its

ining the Maxwell materials from Boies Schiller, the Maxwell Protective Order explicitly provides that (1) di

fairness to the defendants, see id. at 602 n.14. In In reNew York Times Co., 828 F.2d 110 (2d Cir. 1987), cited with approval in United States v. Longueuil, 567 Fed. App'x 13,16 (2d Cir. 2014), Judge Weinstein denied the media's motion to unseal papers filed in connection with an unsuccessful defense mo

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

criminal 4 EFTA00017078 --- PAGE BREAK --- casceamgQAR6nag'49kcnenbt•NeffFiWo*lieZt3&@f2V2f?an§ef61•9f 10 investigations. See United States v. Longueuil, 567 F.App'x 13, 16 (2d Cir. 2014) (finding it was not an abuse of discretion to allow continued sealing of discovery materials that were not judici

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

he integrity of criminal investigations and the privacy and safety of witnesses and suspects that are part of those investigations. United States v. Longueuil, 567 F. App'x 13, 16 (2d Cir. 2014) (holding that district court properly sealed contested documents "as they reflected sensitive information about