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,

utyl Ether (MTBE) Prods. Liab. Litig., MDL No. 1358, 2013 WL 3531600 (S.D.N.Y. July 12, 2013) 10 In re NASDAQ Market-Makers Antitrust Litig., 164 F.R.D. 346 (S.D.N.Y. 1996) 7 ii EFTA00805409 Case 1:15-cv-07433-RWS Document 936 Filed 04/06/18 Page 4 of 21 In re Onusicom Grp., Inc. Sec. Litig., No. 0

bpoena. The application is granted. I. Background A. The Protective Order In September 2015, Virginia L. Giuffre commenced a civil suit against Ghislaine Maxwell, alleging that Maxwell had defamed Giuffre by stating that Giuffre was not the victim of sex crimes perpetrated by, among others, Maxwell a

e application is granted. I. Background A. The Protective Order In September 2015, Virginia L. Giuffre commenced a civil suit against Ghislaine Maxwell, alleging that Maxwell had defamed Giuffre by stating that Giuffre was not the victim of sex crimes perpetrated by, among others, Maxwell and Jeffre

onable, where a protective order is, as here, a blanket order entered by stipulation of the parties." In re NASDAQ Mkt.-Makers Antitrust Litig., 164 F.R.D. 346, 356 (S.D.N.Y. 1996). As for the last factor, the nature of the parties' reliance on the order does seem to weigh against modification. "The classi

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

onable, where a protective order is, as here, a blanket order entered by stipulation of the parties." In re NASDAQ Mkt.-Makers Antitrust Litig., 164 F.R.D. 346, 356 (S.D.N.Y. 1996). As for the last factor, the nature of the parties' reliance on the order does seem to weigh against modification. "The classi