Epstein Secrets

New York The Silvio J. Mono Building One Saint Andrew's Plaza New York. New York 10007 February 28, 2

proceeding such as in Subpoena Duces Tecum-relied upon the Protective Order to indefinitely keep the relevant materials hidden. In this case, where the Protective Order is limited by its terms to only the pretrial stages of the civil litigation, no confidential business information appears to be at issue, and counse

edu) Sigrid S. McCawley ([email protected]) Andrew G. Celli ([email protected]) David Lebowitz (

c disclosure of any sealed or redacted summary judgment materials. The OTSC is, however, incomplete because the dozens of individuals who relied on the Protective Order had no notice of the Order and have had no opportunity to respond. We interpose the following general objections: 1. All sealed and redacted summa

New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 February 28, 2

proceeding such as in Subpoena Duces Tecwn—relied upon the Protective Order to indefinitely keep the relevant materials hidden. In this case, where the Protective Order is limited by its terms to only the pretrial stages of the civil litigation, no confidential business information appears to be at issue, and counse

eading a text in a way that makes part of it redundant," Nat'l Ass'n of Home BuildersI, Defenders of Wildlife 551 U.S. 644 (2007) (citing TRW Inc. Andrews 534 U.S. 19, 31 (2001)), and the canon that "where words are employed in a statute which had at the time a well-known meaning ... in the law of this

s they agreed to be bound by a Protective Order. Each victim (or her attorney) was provided with notice of the Court's ruling, and several executed the Protective Order and were provided with copies of the Non-Prosecution Agreement. From the beginning, Epstein has "vigorously defended" the suits, and has filed seve

New York The Silvio J. Mediu Building One Saint Andrew's Plaza New York. New York 10007 February 28, 2

proceeding such as in Subpoena Duces Tecwn—relied upon the Protective Order to indefinitely keep the relevant materials hidden. In this case, where the Protective Order is limited by its terms to only the pretrial stages of the civil litigation, no confidential business information appears to be at issue, and counse

New York The Silvio J. Mediu Building One Saint Andrew's Plaza New York. New York 10007 February 28, 2

proceeding such as in Subpoena Duces Tecwn—relied upon the Protective Order to indefinitely keep the relevant materials hidden. In this case, where the Protective Order is limited by its terms to only the pretrial stages of the civil litigation, no confidential business information appears to be at issue, and counse

enies Epstein Tie,” New York Post, Oct. 6, 2007; “Andrew Pal Faces Sex List Shame,” Mail on Sunday, Oct.

d by a Protective Order entered by the Court. If [the victim] would like to review the Agreement, please let me know, and I will forward a copy of the Protective Order for her signature. The government shared draft versions of the September letter with Epstein’s counsel and responded to criticism of the content o

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

mmon law right of access, or of the more robust First Amendment right to access certain judicial documents. Id. at 119-20. It is a given accepted by the Protective Order that the trial and all trial documents are accessible and public absent special circumstances. *8 1121 II3IUnder the common law approach, once a do