Epstein Secrets

fferent news outlets (some of which he was likely paid for) 14, and he sat for an interview as part of an hour-long "documentary" called "Ghislaine, Prince Andrew and the Paedophile," which aired on the British channel ITV. He has engaged on Twitter with the journalist who wrote about him, and he has communic

hour-long "documentary" called "Ghislaine, Prince Andrew and the Paedophile," which aired on the British

or not to enter [a] protective order"). The fact that Juror No. 50 filed these pleadings does not make them "judicial documents." United States v. Amodeo ("Amodeo I'), 44 F.3d 141, 145 (2d Cir. 1995) ("We think that the mere filing of a paper or document with the court is insufficient to 54 EFTA0015

om) Sanford L. Bohrer ([email protected]) Andrew G. Celli ([email protected]) David Lebowitz (

nt third parties as well as those of defendants that may be harmed by disclosure . . . should weigh heavily in a court's balancing equation.. .."); Amodeo, 71 F.3d at 1050 ("We have previously held that the privacy interests of innocent third parties . . . should weigh heavily in a court's balancing e

and will not become part of the public record. Andrew Levi, a partner at Lehr Levi & Mendez in Miami an

ty Co.. Excalibur Reinsurance Corp., No. 3:1 I-CV-1209 (CSH) (D. Conn. Aug. 5, 2013), 2013 U.S. Dist. LEXIS 110400, at *37, quoting United States', Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995). These principles are vitally important here where counsels' private communications with prosecutors "if publicl

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

r district court to edit and redact judicial document to allow access to appropriate portions after weighing competing interests); United States v. Amodeo. 71 F.3d 1044 (2d Cir. 1995) ("Amodeo 11") (presumption of access afforded to particular document filed with court varies with document's relevance

Inc., 121 F.3d 818 (2d Cir. 1997) (sealing file pursuant to confidentiality agreement between parties was not abuse of discretion); United States v. Amodeo, 44 F.3d 141 (2d Cir. 1995) ("Amodeo I") (finding it proper for district court to edit and redact judicial document to allow access to appropriate p

dence, a "judicial document" is an item "relevant to the performance of the judicial function and useful in the judicial process." United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995). A common law presumption of access attaches to any judicial document, and an additional First Amendment right ari

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

New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 August 21, 202

ptively accessible, can be kept from the public if their dissemination might 'adversely affect law enforcement interests.") (citing United States v. Amodeo, 71 F.3d 1044, 1050)); see also United States v. Park, 619 F. Supp. 2d 89, 94 (S.D.N.Y. 2009) (holding that the need to "maintain the secrecy of th

Salt Lake City, UT 84112 [email protected] Andrew G. Celli David Lebowitz Emery Celli Brinkerhoff

h dispositive motions such as motions for dismissal or summary judgment." Brown v. Maxwell, 929 F.3d 41, 50 (2d Cir. 2019) (citing United States v. Amodeo, 71 F.3d 1044, 1049-50 (2d Cir. 1995) ("Amodeo II")); (b) any minimum presumption of public access is subject to many countervailing interests suppo

f New York The Salo ..l. Mao Building One Saint Andrew's Plaza New York New Tont 10007 April 30, 2021

Second Circuit has explained that 'the public has an especially strong right of access to evidence introduced in trials."' (quoting United States v. Amodeo, 71 F.3d 1044, 1049 (2d Cir. 1995) (internal quotation marks and citation omitted)). Finally, although the Government is mindful of privacy interes