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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
Page: EFTA00017074 →F NEW YORK Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-RWS
Page: EFTA00017074 →r Christine N. Walz 31 West 52nd Street New York, NY 10019 Telephone: 212.513.3200 Fax: 212.385.9010 Attorneys for Intervenors Julie Brown and Miami Herald Media Company EFTA00017074 --- PAGE BREAK --- casQac,./g%261'43g-ceg‘FenbegrrieRFA004lieif36643026'act6@f218f 10 Pursuant to this Court's Order and protocol f
Page: EFTA00017074 →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
Page: EFTA00017075 →mi Herald") respectfully submit this response to Ms. Maxwell's Memorandum Brief in Support of Her Objections t
Page: EFTA00017075 →Square - NYC) V. Maxwell PLAINTIFF: DEFENDANT: Ghislaine Maxwell (Terminated 5/25/2017) Applicant: John S
@ 2018 CourtLink Corporation UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK (Foley Square - NYC) V. Maxwell PLAINTIFF: DEFENDANT: Ghislaine Maxwell (Terminated 5/25/2017) Applicant: John Stanley Pottinger Interested Party: NYP Rings, •lmrI Daily News, L.P. Intervenor: Michael Cernovich d/b/a
RN DISTRICT OF NEW YORK (Foley Square - NYC) V. Maxwell PLAINTIFF: DEFENDANT: Ghislaine Maxwell (Termin
MATIONAL PURPOSES ONLY'"` Copyright @ 2018 CourtLink Corporation UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK (Foley Square - NYC) V. Maxwell PLAINTIFF: DEFENDANT: Ghislaine Maxwell (Terminated 5/25/2017) Applicant: John Stanley Pottinger Interested Party: NYP Rings, •lmrI Daily News,
017) Applicant: John Stanley Pottinger Interested Party: NYP Rings, •lmrI Daily News, L.P. Intervenor: Michael Cernovich d/b/a Cernovich Media; Miami Herald Media Company; Julie Brown; Alan M. Dershowitz Material Witness: Miscellaneous: Respondent: Sharon Churcher; Jeffrey Epstein DOCKET CASE NUMBER: 1:15cv7433
@ 2018 CourtLink Corporation UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK (Foley Square - NYC) V. Maxwell PLAINTIFF: DEFENDANT: Ghislaine Maxwell (Terminated 5/25/2017) Applicant: John Stanley Pottinger Interested Party NYP Holdings, Inc.,: Daily News, L.P. Intervenor: Michael Cernovich d/
RN DISTRICT OF NEW YORK (Foley Square - NYC) V. Maxwell PLAINTIFF: DEFENDANT: Ghislaine Maxwell (Termin
Square - NYC) V. Maxwell PLAINTIFF: DEFENDANT: Ghislaine Maxwell (Terminated 5/25/2017) Applicant: John S
MATIONAL PURPOSES ONLY'"` Copyright @ 2018 CourtLink Corporation UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK (Foley Square - NYC) V. Maxwell PLAINTIFF: DEFENDANT: Ghislaine Maxwell (Terminated 5/25/2017) Applicant: John Stanley Pottinger Interested Party NYP Holdings, Inc.,: Daily Ne
) Applicant: John Stanley Pottinger Interested Party NYP Holdings, Inc.,: Daily News, L.P. Intervenor: Michael Cernovich d/b/a Cernovich Media; Miami Herald Media Company; Julie Brown; Alan M. Dershowitz Material Witness Miscellaneous: Respondent: Sharon Churcher; Jeffrey Epstein DOCKET CASE NUMBER: 1:15cv7433
October, two thousand twenty. PRESENT: Jost A. CABRANES, ROSEMARY S. POOI.ER, REENA RAGGI, Circuit Judges. Phrinifff-Appellee, 20-2413-cv v. GHISLAINE MAXWELL, Defendant-Appellant, SHARON CHURC:HER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, MICHAEL CERNOVICH, DBA CERNOVICH
Page: EFTA00018289 →udges. Phrinifff-Appellee, 20-2413-cv v. GHISLAINE MAXWELL, Defendant-Appellant, SHARON CHURC:HER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, MICHAEL CERNOVICH, DBA CERNOVICH MEDIA, Intervenors. EFTA00018289 --- PAGE BREAK --- Case 20-2413. Document 140-1, 10/19/2020, 2955244, Page2
Page: EFTA00018289 →FIRMED. Defendant-Appellant Ghislaine Maxwell appeals from a July 23, 2020 order unsealing certain litigation materials, including, and related to, Maxwell's April 2016 deposition transcript. She argues that the District Court abused its discretion in ordering the unsealing of the deposition materials.
Page: EFTA00018290 →be and hereby is AFFIRMED. Defendant-Appellant Ghislaine Maxwell appeals from a July 23, 2020 order unseal
Page: EFTA00018290 →s Courthouse, 40 Foley Square, in the City of New York, on the 11th day of September, two thousand twenty. Plaintiff:Appellee, ORDER v. 20-2413 Ghislaine Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovi
Page: EFTA00028060 →ed by Defendant-Appellant Ghislaine Maxwell and (2) Defendant-Appellant Ghislaine Maxwell's motion to consolidate this appeal with United States v. Maxwell, No. 20-3061. The United States shall submit its brief no later than Wednesday, September 16, 2020 at 3:00 pm. It is also hereby ORDERED that the p
Page: EFTA00028060 →twenty. Plaintiff:Appellee, ORDER v. 20-2413 Ghislaine Maxwell, Defendant-Appellant. Sharon Churcher,
Page: EFTA00028060 →ty. Plaintiff:Appellee, ORDER v. 20-2413 Ghislaine Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Media, Intervenors. It is hereby ORDERED that the United States shall submit an amicus letter
Page: EFTA00028060 →twenty. Plaintiff-Appellee, ORDER v. 20-2413 Ghislaine Maxwell, Defendant-Appellant. Sharon Churcher,
ef, not to exceed ten (10) double-spaced pages, regarding (I) arguments raised by Defendant-Appellant Ghislaine Maxwell and (2) Defendant-Appellant Ghislaine Maxwell's motion to consolidate this appeal with United States v. Maxwell, No. 20-3061. The United States shall submit its brief no later than Wednesday, Sep
ed by Defendant-Appellant Ghislaine Maxwell and (2) Defendant-Appellant Ghislaine Maxwell's motion to consolidate this appeal with United States v. Maxwell, No. 20-3061. The United States shall submit its brief no later than Wednesday, September 16, 2020 at 3:00 pm. It is also hereby ORDERED that the p
ty. Plaintiff-Appellee, ORDER v. 20-2413 Ghislaine Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Media, Intervenors. It is hereby ORDERED that the United States shall submit an amicus letter
to the FBI. Epstein, 54, leads a hedonistic lifestyle that has troubled Royal courtiers ever since ne was introduced to the Prince by their friend Ghislaine Maxwell, daughter of the late disgraced media tycoon Robert Maxwell. During his Thai holiday with Epstein, Andrew was photographed surrounded by topless wo
n Ghislaine Maxwell, daughter of the fat and fraudulent former owner of the Daily News, the late Robert Maxwell. I hear that some of the 39-year-old Ghislaine's friends on the Manhattan and London party circuit are cutting her because she's had so much adverse press over her relationship with Prince Andre
funds. Ghislaine's own funds are something of a mystery. Her father lavished money on her and set her up in at least one business in New York. But Maxwell's own ill-gotten gains were seized after he took a dive off his yacht, which was named for her. There are plenty of British pensioners who lost thei
his Palm Beach home that sometimes became sexual. He also faces state and federal lawsuits filed by several women over similar allegations. O 2008 Miami Herald Media Company. All Rights Reserved. http://www.miamiherald.com http://www.miamiherald.com/news/nation/AP/v-print/story/588587.html 7/1/2008 EFTA01713473 Paln
twenty. Plaintiff-Appellee, ORDER v. 20-2413 Ghislaine Maxwell, Defendant-Appellant. Sharon Churcher,
ef, not to exceed ten (10) double-spaced pages, regarding (I) arguments raised by Defendant-Appellant Ghislaine Maxwell and (2) Defendant-Appellant Ghislaine Maxwell's motion to consolidate this appeal with United States v. Maxwell, No. 20-3061. The United States shall submit its brief no later than Wednesday, Sep
ed by Defendant-Appellant Ghislaine Maxwell and (2) Defendant-Appellant Ghislaine Maxwell's motion to consolidate this appeal with United States v. Maxwell, No. 20-3061. The United States shall submit its brief no later than Wednesday, September 16, 2020 at 3:00 pm. It is also hereby ORDERED that the p
ty. Plaintiff-Appellee, ORDER v. 20-2413 Ghislaine Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Media, Intervenors. It is hereby ORDERED that the United States shall submit an amicus letter
ef, not to exceed ten (10) double-spaced pages, regarding (I) arguments raised by Defendant-Appellant Ghislaine Maxwell and (2) Defendant-Appellant Ghislaine Maxwell's motion to consolidate this appeal with United States v. Maxwell, No. 20-3061. The United States shall submit its brief no later than Wednesday, Sep
ed by Defendant-Appellant Ghislaine Maxwell and (2) Defendant-Appellant Ghislaine Maxwell's motion to consolidate this appeal with United States v. Maxwell, No. 20-3061. The United States shall submit its brief no later than Wednesday, September 16, 2020 at 3:00 pm. It is also hereby ORDERED that the p
twenty. Plaintiff-Appellee, ORDER v. 20-2413 Ghislaine Maxwell, Defendant-Appellant. Sharon Churcher,
ty. Plaintiff-Appellee, ORDER v. 20-2413 Ghislaine Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Media, Intervenors. It is hereby ORDERED that the United States shall submit an amicus letter
ip to Epstein. Little is known about Epstein except that his offices are in the landmarked Villard House across from Le Cirque, and he once employed Ghislaine Maxwell, daughter of the late British press lord Robert Maxwell, in an unspecified capacity. But Tucker is playing America's first black president in "Mr.
t Side dinners," the woman recalls. "Many seemed foreign and dressed a little bizarrely." This same guest also at- tended a cocktail party thrown by Maxwell that Prince Andrew attended, which was filled, she says, with young Russian models. "Some of the guests were horri- fied," the woman says. "He's re
ouse across from Le Cirque, and he once employed Ghislaine Maxwell, daughter of the late British press lord
his Palm Beach home that sometimes became sexual. He also faces state and federal lawsuits filed by several women over similar allegations. @ 2008 Miami Herald Media Company. All Rights Reserved. http://www.miamihcrald.com html 7/1/2008 EFTA00188447 ILLVI IV" LIM EFTA00188448 MR. BIG Jeffrey Epstein in Ness Yor
Entities connected to both Ghislaine Maxwell and Miami Herald Media Company

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
United States
LOCATION
George W. Bush
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Department of Justice
ORGANIZATION
Marc Rich
PERSON
Donald Trump
PERSONLeon Black
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Eric Trump
PERSON
Julie K. Brown
PERSON
Virginia Giuffre
PERSONMaria Farmer
PERSON
Les Wexner
PERSONDoug Band
PERSON
Joe Biden
PERSON
Vicky Ward
PERSON