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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,
MAXWELL The Miami Herald is the second largest newspaper in South Florida. Established in 1903, it is circulated in Miami-Dade, Broward County, and Monroe County, as well as in the Caribbean and Latin America. Julie Brown is an investigative journalist at the Miami Herald with over twenty years of experience
Judge Denies Bail Request. The CBS Evening NewsVI (7/14, story 12, 1:30, O'Donnell, 4.31M) reported, "Today, a federal judge in New York ruled that Ghislaine Maxwell has both the money and the motive to flee the country, and denied her request to be freed on bail. It means the alleged accomplice of accused sex t
bars since her July 2nd arrest. US District Judge Alison Nathan determined the 58-year-old British socialite should not be released on bail, saying Maxwell is a substantial EFTA00150068 actual risk of flight. Prosecutors say Maxwell has links to more than a dozen bank accounts around the world worth
14 for abuse by' convicted sex offender Jeffrey Epstein in the 1990s. The prosecutor read one of the alleged victim's statement in court. `Without Ghislaine, Jeffrey could have not done what he did. She was a predator and a monster.' A second victim, Annie Farmer, chose to speak, publicly identifying her
"The hearing was unusual in that it was virtual: Ms. Maxwell, who is being held in a federal detention center
." According to ABC News, "Attorneys for Sean Purdy, one of the men accused of taking part in the alleged assault, held a news conference Monday in Monroe County, Indiana, and said Booker was putting out 'a false narrative' about the incident that took place in Lake Monroe." FBI Arrests Fugitive In Miami Aft
Spying. Criminal Investigations • Judge Denies Ghislaine Maxwell's Bid To Keep Records Sealed. • Mississippi Man Ch
y embarrassing documents from a settled defamation suit." The Herald adds, "Hours before the start of their scheduled unsealing on Thursday morning, Maxwell's lawyers filed a motion to reconsider before U.S. District Judge Loretta Preska, challenging her July 23 decision to order the unsealing and releas
Spying. Criminal Investigations • Judge Denies Ghislaine Maxwell's Bid To Keep Records Sealed. • Mississi
thers that are keeping campuses closed." Miami Dade County schools Superintendent Alberto Carvalho "announced the move Wednesday, a day after nearby Monroe County said it would rely on digital instruction for the immediate future." Schools in Broward and Palm Beach counties "also intend to start the school ye
lenge should be dismissed." Lord Justice Bean and Mr Justice Lewis "are expected to deliver a ruling in the near future." CRIMINAL INVESTIGATIONS Ghislaine Maxwell Reportedly Refuses To Reveal Name Of Spouse To FBI. The London (UK) Evening Standard (7/15, Somerville, 856K) reports, "Ghislaine Maxwell is secret
to charges she had trafficked at least three underage girls for billionaire paedophile Jeffrey Epstein." Assistant US Attorney Alison Moe "revealed Maxwell had a spouse while questioning who would co-sign her bond at a bail hearing in New York. She told the courthouse late on Tuesday: 'In addition to fa
dges' Inquest Ruling. CRIMINAL INVESTIGATIONS • Ghislaine Maxwell Reportedly Refuses To Reveal Name Of Spou
ecutors on Wednesday for review, officials said." According to Reuters, "The contents of the submission were not immediately made public," but "the Monroe County Prosecuting Attorney's Office is expected to evaluate evidence it received to decide whether to bring charges in the incident this month." Reuters a
s federal authorities announced Friday that Adam Maxwell Donn of Norfolk, Virginia "has been charged with
on," while Jerry Cox II "was charged with felony criminal confinement and battery resulting in moderate bodily injury, as well as two misdemeanors." Monroe County Prosecuting Attorney Erika Oliphant said warrants have been put out for their arrests. ABC News (7/17, 2.97M) reports, "Indiana prosecutors on Frid
rganizer's Guide to Executive Action," Mary Beth Maxwell, executive director of Workshop, demystifies and
mon) reported that Thomas David Carruth, 64, of Clarendon, Arkansas has been convicted of one count of making false statements on Friday. The former Monroe County district court judge presided over criminal and civil matters during his time in office. In April 2022, Carruth solicited sex from the girlfriend o
Entities connected to both Ghislaine Maxwell and Monroe County

Jeffrey Epstein
PERSON
Prince Andrew
PERSONSouthern District
LOCATION
United States
LOCATION
George W. Bush
PERSON
Bill Clinton
PERSON
Newark
LOCATION
Alan Dershowitz
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATION
FedEx
ORGANIZATION
Marc Rich
PERSON
Donald Trump
PERSONLeon Black
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Eric Trump
PERSON
Julie K. Brown
PERSONDarren Indyke
PERSON
Virginia Giuffre
PERSON