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

ed to achieve that aim."13 " Bernstein v. Bernstein Litowitz Berger & Grossmann LLP, 814 F.3d 132, 139 (2d Cir. 2016). 12 Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 121 (2d Cir. 2006). We observe that our holding in Lugosch relies on the general principle that parties may "be assumed to have supp

P ("Boies Schiller") to comply with a grand jury subpoena. The application is granted. I. Background A. The Protective Order In September 2015, Virginia L. Giuffre commenced a civil suit against Ghislaine Maxwell, alleging that Maxwell had defamed Giuffre by stating that Giuffre was not the victim of sex crime

A. The Protective Order In September 2015, Virginia L. Giuffre commenced a civil suit against Ghislaine Maxwell, alleging that Maxwell had defamed Giuffre by stating that Giuffre was not the victim of sex crimes perpetrated by, among others, Maxwell and Jeffrey Epstein ("Epstein"). (15-cv- 7433, Dkt. N

und A. The Protective Order In September 2015, Virginia L. Giuffre commenced a civil suit against Ghislai

eason for the Government to carry the firm's water—the moreso because Judge Sweet ruled some months before he died that the intervenors' appeals in Giuffie meant the lawsuit had not "concluded," and so had postponed the day when that contractual obligation kicked in. (15-cv-7433, Dkt. No. 967 at 6.)3 3

igation" did "not lend itself to reasonable reliance that [the Protective Order] will afford permanent secrecy." See also Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 126 (2d Cir. 2006), where, in view of a provision that said, "This Confidentiality Order shall not prevent anyone from applying to t

5439090 (S.D.N.Y. Aug. 10, 2015) 7 In re Terrorist Attacks on Sept. 11, 2001, 454 F. Supp. 2d 220 (S.D.N.Y. 2006) 15 Landmark Commcins, Inc. v. Virginia, 435 U.S. 829 (1978) 10 Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) passim Mitchell v. Fishbein, 227 F.R.D. 239 (S.D.N.Y.

iminal case against Mr. Epstein, which include the now-settled above-captioned action. Here, the underlying claim is a defamation action brought by Virginia Giuffre ("Ms. " or "Plaintiff') against Ghislaine Maxwell ("Ms. Maxwell" or "Defendant") on the grounds that Ms. Maxwell, in coordination with Mr. Epstein

claim is a defamation action brought by Virginia Giuffre ("Ms. " or "Plaintiff') against Ghislaine Maxwe

n Sept. 11, 2001, 454 F. Supp. 2d 220 (S.D.N.Y. 2006) 15 Landmark Commcins, Inc. v. Virginia, 435 U.S. 829 (1978) 10 Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) passim Mitchell v. Fishbein, 227 F.R.D. 239 (S.D.N.Y. 2005) 15 Nebraska Press Ass'n v. Stuart, 427 U.S. 539 (1976

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,

in a court is whether it is a "judicial document." Trump v. Deutsche Bank AG, 940 F.3d 146, 150-51 (2d Cir. 2019) (citing Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119 (2d Cir. 2006)). Merely filing a document with a court "'is insufficient to render that paper a judicial document subject to the

Ghislaine Maxwell's Appendix is cited as "App." Virginia Giuffre's Supplemental Appendix is cited as "SA." EFTA0009

rt's September 11, 2020, order directing the parties to respond to the Government's amicus letter brief filed on September 16, 2020. D.E. 113.1 Ms. Giuffre agrees with the Government's position and opposes Defendant's motion to consolidate this appeal (the "civil appeal") with her appeal in United Stat

States Court of Appeals for the Second Circuit VIRGINIA L GIUFFRE, —against- GHISLAINE MAXWELL, Plainti

"The common law 4 EFTA00095339 right to public access to judicial documents is firmly rooted in our nation's history." Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119 (2d Cir. 2006). This Court explained that this Circuit's "public access cases and those in other circuits emphasize the importan

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

ng is necessary to preserve higher values and only if the sealing order is narrowly tailored to achieve that aim."I3 12 Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 121 (2d Cir. 2006). We observe that our holding in Lugosch relies on the general principle that parties may "be assumed to have sup

ates have deployed attack-trained dogs on prisoners in recent years — Arizona, Connecticut, Delaware, Indiana, Iowa, Massachusetts, New Jersey, and Virginia. According to the article, over the past six years, hundreds of incarcerated people have been bitten or mauled. The article highlighted that a 2005

may have known some Oneida Nation members, was gang-raped and killed. The article stated that FBI agents reportedly made visits to residents of the Onondaga reservation, a bigger Native American territory 40 miles from the Oneida Nation Territory, as recently as last week in their latest efforts to pers

entist of the Year" by the Mid-Atlantic Association of Forensic Scientists ■ Recipient of the United States Attorney's Office Eastern District of Virginia "Law Enforcement Public Service Award" ■ Recipient of the FBI Director's Award of Excellence for Outstanding Scientific Advancement EFTA00073053

Case#08-CR-00001 22. Blau v. Schaefer, MD (Docket MID-L-3015-05) New Jersey (Deposition) 23. People of the State of NY v Stacey Castor County of Onondaga Syracuse, NY, DR#05-359834/07-402152 24. International Arbitration. Bank Julius Baer Co. Ltd v Waxfield Ltd Lie Bbcfd Sa G 04-6668-Cv 424 F.3d 278