Epstein Secrets

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,

partially redacted, and the order denying the motion to unseal was itself sealed. The second individual, podcast host and investigative journalist Michael Cemovich, moved to intervene and unseal Defendant's Motion for Summary Judgment (the "Cemovich Motion"). (ECF No. 550.) The portion of the Cemovich motion se

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

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,

slaine 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 brief, not to exceed ten (10) double-s

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

slaine 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 brief, not to exceed ten (10) double-s

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,

slaine 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 brief, not to exceed ten (10) double-s

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

slaine 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 brief, not to exceed ten (10) double-s

has filed an application for modification of a March 18, 2016 pretrial protective order, entered by the late Hon. in a civil defamation action, v. Maxwell, No. 15-cv-7433 (S.D.N.Y.) ("the Action"), in order to permit the law firm of Boles Schiller Flexner LLP ("Boies Schiller") to comply with a grand

ith a grand jury subpoena. The application is granted. I. Background A. The Protective Order In September 2015, commenced a civil suit against Ghislaine Maxwell, alleging that Maxwell had defamed by stating that was not the victim of sex crimes perpetrated by, among others, Maxwell and Jeffrey Eps

ein, moved to unseal a limited portion of the record in order to clear his name. (15-cv-7433, Dkt. No. 364 at 1.) Alt-right activist and provocateur Michael Cemovich also sought to unseal the papers filed as part of Maxwell's motion for summary judgment, arguing, "Cemovich Media cannot conduct its Forth [sic] Es

RNEYS AT LAW 600 FIFTH AVENUE. AT ROCKEFF.U.F.R a:Nita 10^, FLOOR NEW YORK, NEW YORK 10020 TEL FAX: vrww.echalaw.com December 3, 2018 Re: v. Maxwell, No. 15 Civ. 7433 (RWS) Dear Judge Sweet: CHARLES1. OGLETREE, JR. EMEWLIS DIANE L. HOUK JESSICA CI.ARKE ALISON FRIOC DAVID LEBOWITZ DOUGLAS E

for over two years. But, because this Court has thrice denied applications for such disclosure (once when made by Mr. Dershowitz; once when made by Michael Cemovich; and a third time when made by the Miami Herald), and because these issues are currently on appeal in the Second Circuit, Mr. Dershowitz asks that

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

OREMAN, P.C., 150 East 10th Avenue, Denver, CO 80203, By: Laura A. Menninger, Esq., Jeffrey S. Pagliuca, Esq., Ty Gee, Esq. Counsel for Intervenor Michael Cemovich: RANDAZZA LEGAL GROUP, PLLC, 100 Pearl Street, 14th Floor, Hartford, CT 06103, By: Jay M. Wolman, Esq. Counsel for Intervenor Alan Dershowitz: EMER

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