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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
ved in an investigation"; "[t]he district court was in the best position to weigh these factors") (internal quotations and citation omitted); In re N.Y. Times Co., 828 F.2d 110,116 (2d Cir.1987) ("Certainly, the privacy interests of innocent third parties as well as those of defendants that may be harmed by d
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,
Page: EFTA00020541 →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
Page: EFTA00020541 →s District Court, S.D. New York. Plaintiff, v. Ghislaine MAXWELL, Defendant. 15 Civ. 7433 i Signed 08/2
Page: EFTA00020541 →her claim of defamation by Maxwell arising out of the Maxwell January 3 Statement. alleged she was the "victim
Page: EFTA00020554 →trating that `closure is essential to preserve higher values and is narrowly tailored to serve that interest,' " the documents may be sealed. In re N.Y. Times Co., 828 F.2d 110, 116 (2d Cir. 1987) (citing Press-Enterprise Co., 464 U.S. at 510, 104 S.Ct. 819). The compelling interest is the privacy interest di
Page: EFTA00020568 →e the charges against him were pending. OA (citing United States v. Epstein 19 Cr. 490 (RMB), Nolle Prosequi (Dkt. No. 52))) B. The Prosecution of Ghislaine Maxwell On June 29, 2020, Ghislaine Maxwell was indicted by a grand jury in this District on "one count of conspiracy to entice minors to travel to engage
Page: EFTA00038654 →Prosequi (Dkt. No. 52))) B. The Prosecution of Ghislaine Maxwell On June 29, 2020, Ghislaine Maxwell was
Page: EFTA00038654 →ntent to engage in criminal sexual activity"; "and two counts of perjury." (Third Comey Decl. (Dkt. No. 59) 1 6) On December 29, 2021, a jury found Maxwell guilty of enticing a minor to travel to engage in illegal sex acts, transporting minors with the intent to engage in criminal sexual activity, and
Page: EFTA00038655 →is that in FOIA actions, agency affidavits alone will support a grant of summary judgment,' and Local Civil Rule 56.1 statements are not required." N.Y. Times Co. v. U.S. Dept. of Justice, 872 F. Supp. 2d 309, 314 (S.D.N.Y. 2012) (quoting Ferguson v. FBI 1995 WL 329307, at •2 (S.D.N.Y. 7 EFTA00038658 --- P
Page: EFTA00038658 →Entities connected to both Ghislaine Maxwell and N.Y. Times Co.

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Julie K. Brown
PERSONLaura Menninger
PERSONFBI
ORGANIZATION
Denver
LOCATIONSigrid McCawley
PERSON
Paul Cassell
PERSONSecond Circuit
ORGANIZATION
Nassau
LOCATIONDistrict Court for the Southern District of New York
ORGANIZATIONFederal Bureau of Prisons
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATION
Andrew Cuomo
PERSON
Salt Lake City
LOCATION
Cynthia Nixon
PERSONSweet
PERSON
Alberto Gonzales
PERSON
the University of Utah
ORGANIZATION