Epstein Secrets

hislaine Maxwell's motion for summary judgment (ECF No. 540 to 543, inclusive); • (b) All currently sealed documents filed in support of Plaintiff Virginia L. Giuffre's opposition to Defendant's motion for summary judgment (ECF No. 586 to 586-3, inclusive); • (c) All currently sealed documents in support of Defen

1 (2d Cir. 2019); Giuffre v. Maxwell, No. 15 Civ. 7433 (RWS) (S.D.N.Y. Nov. 2, 2016), ECF No. 496 (Opinion Granting Dershowitz Motion to Intervene); Giuffre v. Maxwell, No. 15 Civ. 7433 (RWS) (S.D.N.Y. May 3, 2017), ECF No. 892 (Opinion Granting Cemovich Motion to Intervene). Intervention may be permitt

ES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell,

be designated a judicial document, "the item filed must be relevant to the performance of the judicial function and useful in the judicial process." Amodeo, 44 F.3d at 145. Judicial documents are considered on a "continuum," ranging from "matters that directly affect an adjudication to matters that com

casgamge26143R-ficsarnecobalrgefiFiW044136§fgheatmbefilth 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-RWS INTERVENORS' JULIE BROWN AND MIAMI HERALD MEDIA CO.'S RESPONSE TO MAXWE

COURT SOUTHERN DISTRICT OF NEW YORK Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant.

limited Martindell's ruling to cases involving documents that were not "judicial documents" subject to a presumption of access. See United States v. Amodeo, 44 F.3d 141 (2d Cir. 1995). 3 EFTA00017077 --- PAGE BREAK --- casQam§feZot4AceguneoUgnieAFP95?044leiPtit§f2V28aftbef51M 10 scandalous." Brown

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

rovides the public and the press a constitutional right of access to all trials, criminal or civil." Id. at 468 (citing Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 580, 100 S.Ct. 2814, 65 L.Ed.2d 973 (1980) ) (internal citation omitted). This right applies specifically to "related proceedings an

DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant.

supporting continued sealing/redaction of the item, and (c) whether the countervailing interests rebut the presumption of public access to the item. Giuffre v. Maxwell, No. 15-CV-07433-LAP, 2020 WL 1547377, at *1 (S.D.N.Y. Mar. 31, 2020); DE 1044.' Based on the Court's clarification of its March 31, 202

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 impairing law enforcement or judicial efficiency' and `the privacy interests of those resisting disclosure.' Id. at 120 (quoting United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995) ("Amodeo IT)). I EFTA00031598 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 168 Filed 03/18/21 Page 2 of

in opposition to the Defendant's pre-trial motions is a "judicial document" for purposes of the first element of the Lugosch test. United States v. Amodeo ("Amodeo I"), 44 F.3d 141, 145 (2d Cir. 1995). The Court thus concludes that there is a common law and a First Amendment presumption of access. Id.

est to file Exhibit 11 entirely under seal. While portions of that transcript have been redacted, other portions are part of the public record. See Giuffre v. Maxwell, Case No. 15-cv-7433, Dkt. No. 1212-1. In light of this, the Court sees no basis to file the transcript entirely under seal rather than b

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

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