Epstein Secrets

cuit AUGUST TERM 2018 No. 18-2868-cv JULIE BROWN, MIAMI HERALD COMPANY, Intervenors-Appellants, v. GHISLAINE MAXWELL, Defendant-Appellee, v. VIRGINIA L. GIUFFRE, Plaintiff-Appellee. No. 16-3945-cv(L) No. 17-1625 (CON) No. 17-1722(CON) ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNOVICH MEDIA

UST TERM 2018 No. 18-2868-cv JULIE BROWN, MIAMI HERALD COMPANY, Intervenors-Appellants, v. GHISLAINE MAXWELL, Defendant-Appellee, v. VIRGINIA L. GIUFFRE, Plaintiff-Appellee. No. 16-3945-cv(L) No. 17-1625 (CON) No. 17-1722(CON) ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNOVICH MEDIA, Interven

otion as moot. 5 The stricken allegations, however, quickly found their way into the press, and several media outlets published articles repeating Giuffre's accusations. In response to the allegations, on January 3, 2015, Maxwell's publicist issued a press statement declaring that Giuffre's allegation

v. GHISLAINE MAXWELL, Defendant-Appellee, v. VIRGINIA L. GIUFFRE, Plaintiff-Appellee. No. 16-3945-cv(L) No. 17-

ist issued a press statement declaring that Giuffre's allegations "against Ghislaine Maxwell are untrue" and that her "claims are obvious lies. "6 B. Giuffre Sues Maxwell On September 21, 2015, Giuffre filed the underlying action against Maxwell in the Southern District of New York. Giuffre alleged that

lize this crucial qualification to the litigation privilege. " Westmoreland v. Columbia Broad. Sys., Inc., 752 F.2d 16, 23 (2d Cir. 1984) (quoting Globe Newspaper Co. v. Superior Court for Norfolk Cty., 457 U.S. 596, 606 (1982)). 49 Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 572-73 (1980) (plurality op

0 Instead, the District Court made generalized statements about the record as a whole.30 This too was legal error. 19 Id. at 124. 20 See. e.g., Giuffre, 325 F. Supp. 3d at 445 (summarily concluding that all "[t]he Summary Judgment Judicial Documents openly refer to and discuss these allegations [o

lobe Newspaper Co. v. Superior Court for Norfolk Cly., 457 U.S. 596, 606, 102 S.Ct. 2613, 73 L.Ed.2d 248 (1982)). 49 Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 572-73, 100 S.Q. 2814, 65 L.Ed.2d 973 (1980) (plurality opinion) (internal quotation marks omitted). At the same time, the media do

its] claim of functioning as surrogates for the public."J9 48 Westmoreland v. Columbia Broad. Sys., Inc., 752 F.2d 16, 23 (2d Cir. 1984) (quoting Globe Newspaper Co. v. Superior Court for Norfolk Cly., 457 U.S. 596, 606, 102 S.Ct. 2613, 73 L.Ed.2d 248 (1982)). 49 Richmond Newspapers, Inc. v. Virginia, 448 U.S.

titutional protections."'Butterworth, 494 U.S. at 630—31 (quoting U.S, v. Dionisio, 410 U.S. 1, 11 (1973)); see also Landmark Communications, Inc. v. Virginia, 435 U.S, 829, 838 (1978) (balancing state’s interest in preserving confidentiality ofjudicial misconduct proceedings against rights of newspaper rep

ntly, public access to trials acts as an important check, akin in purpose to the other checks and balances i that infuse our system of government.”); Globe Newspaper Co. v. Superior Courtfor Norfolk County, 457 U.S. 596, 606 (1982) (“the right of access to criminal trials plays a particularly significant role in the f

terprise Co. v. Superior Court, 464 U.S. 501 (1984) Press-Enterprise Co. v. Superior Court, 478 U.S. 1 (1986) 13 11 Richmond Newspaper& Inc. v. Virginia, 448 U.S. 555 (1980) 12, 13 Constitutions U.S. Const. amend. I 11 N.Y. State Const. art. I. § 8 11 Statutes N.Y. Civ. Rights Law § 50-b N.Y

6 N.Y.S.3d 19 (1st Dep't 2015) 10 Danco Labs., Ltd v. Chem. Works of Gideon Richter, Ltd, 274 A.D.2d 1, 711 N.Y.S.2d 419 (1st Dep't 2000) 11, 13 Globe Newspaper Co. v. Superior Court, 457 U.S. 596 (1982) 11, 13 In re Application of National Broad Co., 635 F.2d 945 (2d Cir. 1980) 11, 13 In re Associated Pres

to public records. The Supreme Court has not yet held that there is a constitutional right to attend civil trials. In Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 100 S.Ct. 2814, 65 L.Ed.2d 973 (1980), the Court held that implicit in the First Amendment is the constitutional right to attend cri

ve information, it must be shown that the denial is necessitated by a compelling governmental interest, and is narrowly tailored to that interest." Globe Newspaper Co. v. Superior Court. 457 U.S. 596 at 606-607, 102 5.0. 2613 at 2620, 73 L.Ed.2d 248 at 257. 6% F.2d at 802. WestlawNext @ 2015 Thomson Reuters. No

et and, at one point, owned a Boeing 727. HOUSE_OVERSIGHT_016444 --- PAGE BREAK --- HOUSE_OVERSIGHT_016445 --- PAGE BREAK --- e = sad Si, = a E Virginia Roberts says she was used as a sex slave for Jeffrey Epstein for years starting at the age of 16. Roberts says that Epstein also lent her out to some of his

45 --- PAGE BREAK --- e = sad Si, = a E Virginia Roberts says she was used as a sex slave for Jeffrey Epstein for years starting at the age of 16. Roberts says that Epstein also lent her out to some of his wealthy, powerful acquaintances for sex. COURTESY OF VIRGINIA ROBERTS He has never been in the Fo

bs., Ltd. v. Chem. Works of Gideon Richter, Ltd., 274 A.D.2d 1, 711 N.Y.S.2d 419 (1st Dep't 2000) oo. eeeeseseeseeseeeeeseeeteeseeeseeseeeees 13, 15 Globe Newspaper Co. v. Superior Court, 457 U.S. 596 (1982)... eeeceesescesseseeseeseeseescscesceseescesceesseeseecseeseseeseeseeaeaseeaeeacseeseesseateaseeeases 13, 14

Second Renewed Motion for Leave to Assert Claim for Punitive Damages; Exhibit “D” — Edwards’ Notice of Filing of Transcript of Telephone Interview of Virginia Roberts in Support of Motion for Leave to Amended to Assert Punitive Damages; Exhibit “E” — Transcript of Deposition of Jeffrey Epstein dated January 25, 20

plead a claim for punitive damages, the claimant must show a “reasonable basis” for the recovery of such damages. See Fla.R.Civ-P. 1.190(f); see also Globe Newspaper Co. v. King, 658 So.2d 518, 520 (Fla. 1995). The showing required to amend is minimal. As stated in State of Wis. Inv. v. Plantation Square Assoc., 761 F

n a sealed The right of access is an affirmative, enforceable public right, and the standing of the press to enforce it is well settled. See, e.g., Globe Newspaper Co. v. Superior Court, 457 U.S. 596, 609 n.25 (1982); Hanford Courant Co. v. Pellegrino, 380 F.3d 83, 91 (2d Cir. 2004). EFTA00017095 --- PAGE BREAK

idence in the judiciary depends on openness of court records and proceedings. On this point, Chief Justice Burger's words in Richmond Newspapers v. Virginia are particularly apt: People in an open society do not demand infallibility from their institutions, but it is difficult for them to accept what th