Epstein Secrets

of New York The SiAdol Mollo Building One Saint Andrew's Plaza New York, New York 10007 October 18, 20

h proposed redactions. The Government's proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although the Government's motions in limine are judicial documents subject to the common law presumption of access, th

y for the Southern District of New York One St. Andrew's Plaza New York, New York 10007 Assistant Unit

Exhibit B, which is Dr. Hall's evaluation of Minor Victim-4, in accordance with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although this brief and the attached exhibit are judicial documents subject to the common law presumption of access,

New York The Silvio!. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 12, 2

of their testimony. ' The Government's proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although this letter is a judicial document subject to the common law presumption of access, the proposed redactions

of New York The SiAdol Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 12, 2

of their testimony. ' The Government's proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although this letter is a judicial document subject to the common law presumption of access, the proposed redactions

document has been historically available (the "experience" prong) and would be valuable to the process in question (the "logic" prong). Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119-20 (2d Cir. 2006). The weight of the common law presumption turns on "the role of the material at issue in the exercise of Artic

All counsel of record (via e-mail) 7 See, e.g., Andrew Denney, Prosecutors to seek death penalty for ex-

Fifth Avenue, 10th Floor, New York, NY 10020, By: Andrew G. Celli, Jr., Esq. I This daytime business add

s." 191 1101 1111Whether discovery or trial, "a court must first conclude that the documents at issue are indeed `judicial documents.' " Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119 (2d Cir. WESTLAW © 2018 Thomson Reuters. No claim to original U.S. Government Works. 21 EFTA00020561 --- PAGE BREAK --- v. M