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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
g]enerally, the presumption of access applies to all documents filed with the court." Under Seal, 273 F. Supp. 3d at 269; see also United States v. Sattar, 471 F. Supp. 2d 380, 385 (S.D.N.Y. 2006) (generally, a document is a "judicial document" if it is "submitted to the Court for the purposes of seeki
. Mot. 7 at 16). She again cites the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obtain materials from the Giuffre civil litigation. (Id.). Leaving aside the fact that, as set forth in Section IV, the Government obtained such materials through a judicially approv
inner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards p
oies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards provided AUSA-1 wi
ted States v. Santiago, 987 F. Supp. 2d 465 (S.D.N.Y. 2013) 75 United States v. Sarwari, 669 F.3d 401 (4th Cir. 2012) 179, 180 United States v. Sattar, 272 F. Supp. 2d 348 (S.D.N.Y. 2003) 27 United States v. Savage, 970 F.3d 217 (3d Cir. 2020) 302 United States v. Scala, 388 F. Supp. 2d 396 (
. Mot. 7 at 16). She again cites the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obtain materials from the Giuffre civil litigation. (Id.). Leaving aside the fact that, as set forth in Section IV, the Government obtained such materials through a judicially approv
inner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards p
oies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards provided AUSA-1 wi
ted States v. Santiago, 987 F. Supp. 2d 465 (S.D.N.Y. 2013) 75 United States v. Sarwari, 669 F.3d 401 (4th Cir. 2012) 179, 180 United States v. Sattar, 272 F. Supp. 2d 348 (S.D.N.Y. 2003) 27 United States v. Savage, 970 F.3d 217 (3d Cir. 2020) 302 United States v. Scala, 388 F. Supp. 2d 396 (
side, the civil matters were in completely different procedural postures, which implicate different concerns regarding a pending criminal case. The Giuffre v. Maxwell litigation was settled and complete well before the Government even opened its investigation in this case. By contrast, the Doe v. Indyk
inner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards p
oies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards provided AUSA-1 wi
ted States v. Santiago, 987 F. Supp. 2d 465 (S.D.N.Y. 2013) 52 United States v. Sarwari, 669 F.3d 401 (4th Cir. 2012) 120, 121 United States v. Sattar, 272 F. Supp. 2d 348 (S.D.N.Y. 2003) 22 United States v. Savage, 970 F.3d 217 (3d Cir. 2020) 210 United States v. Scala, 388 F. Supp. 2d 396 (
S. Attorney's Office for the Eastern District of Virginia"); Gonzalez, 93 F. App'x at 270 ("Paragraph 13 ex
6) 12 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 20, 21, 23 United States v. Salameh, 152 F.3d 88 (2d Cir. 1998) 22 United States v. Sattar, No. 02 Cr. 395 (JGK), 2003 WL 22510398 (S.D.N.Y. Nov. 5, 2003) 29 United States v. Van Thornout, 100 F.3d 590 (8th Cir. 1996) 24 United States
S. Attorney's Office for the Eastern District of Virginia"); Gonzalez, 93 F. App'x at 270 ("Paragraph 13 ex
6) 12 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 20, 21, 23 United States v. Salameh, 152 F.3d 88 (2d Cir. 1998) 22 United States v. Sattar, No. 02 Cr. 395 (JGK), 2003 WL 22510398 (S.D.N.Y. Nov. 5, 2003) 29 United States v. Van Thornout, 100 F.3d 590 (8th Cir. 1996) 24 United States
Entities connected to both Virginia Giuffre and Sattar

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATION
George W. Bush
PERSON
United States
LOCATION
Bradley Edwards
PERSONJane Doe
PERSON
Julie K. Brown
PERSON
New York
LOCATIONthe Southern District
LOCATIONMaria Farmer
PERSON
Colorado
LOCATIONFBI
ORGANIZATION
Scarlett Johansson
PERSON
Michael Jackson
PERSON
George Mitchell
PERSON
Michigan
LOCATIONEmmy Taylor
PERSON
Alexander Acosta
PERSON