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,

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 seeking to unseal the Motion for Summary Judgment was also denied. 5 EFTA00805416 Case 1:15-cv-07433-RWS Document 936 Filed 04/06/18 Page

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

rvenor- Appellant Michael Cernovich. JOSE A. CABRANES, Circuit Judge: Intervenors-Appellants Alan M. Dershowitz ("Dershowitz"), Michael Cemovich ("Cemovich"), and the Miami Herald Company (with reporter Julie Brown, jointly the "Herald") appeal from certain orders of the United States District Court fo

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

n April 27, 2017 (the "Redacted Opinion"). See Redacted Opinion, April 27, 2017, ECF No. 872. *4 On January 19, 2017, Intervenor Michael Cemovich ("Cemovich" or "Intervenor Cemovich") made a motion to unseal the materials submitted in connection with Maxwell's motion for summary judgment, which the Cour