Epstein Secrets

EW YORK Plaintiff, - against - GHISLA1NE MAXWELL, Defendant. : Case No. 15-cv-7433 (RWS) MEMORANDUM OF LAW IN SUPPORT OF PROPOSED INTERVENORS JULIE BROWN AND MIAMI HERALD MEDIA COMPANY'S MOTION TO INTERVENE AND UNSEAL 1 EFTA00805407 Case 1:15-cv-07433-RWS Document 936 Filed 04/06/18 Page 2 of 21

OF LAW IN SUPPORT OF PROPOSED INTERVENORS JULIE BROWN AND MIAMI HERALD MEDIA COMPANY'S MOTION TO INTER

nesses, endanger national security, reveal trade secrets, or implicate duty to protect attorney-client material or confidential client information); Hardy, 2017 WL 6805707, at *6-7 (unsealing transcript of settlement between workers' union and, inter alia, the Trump Organization and holding that, unde

eserve any 'special treatment' and that her actions over the last year prove she is an 'extraordinary' flight risk." The New York Daily News (7/13, Brown, 2.52M) also reports. PROTESTS Trump Criticizes "Anti-Cop Crusade" By Democrats. The Washington Times (7/13, Boyer, 492K) reports President Trump

rces in identifying the estimated sale price." FBI Continues Probe Of Independence, Missouri Government. The Kansas City (MO) Star (7/13, Hancock, Hardy, Vockrodt, 549K) reports, "The FBI has once again requested records from Independence City Hall, the latest in a series of inquiries by federal aut

n r -C) 2' 1"" tea rn PI 0 - n r O - -c BROWN MAY 162001 0 3 —c Ce? cn cn EFTA00229662

name to Lefkowitz. I told him that he was mutual friends with two people whom I respected. I also told Leflcowitz that Ocariz worked at the Shook, Hardy, and Bacon finn, and that he had worked with Guy Lewis, another of Epstein's attorneys. Later, Leflcowitz called me and said that he had checked on

a duty implied by or arising out of a contract." Brown-Marx Associates. Ltd. v. Emigrant Say. Bank, 703

failed to advise the Plaintiff as to Specialty's financial troubles. (Id.) The Plaintiffs claims are firmly grounded in tort, even more so than in Hardy, because the claims here involve duties arising primarily from the circumstances of the working relationship between the parties. See infra § III.C

presumption applied to material introduced at trial, or in connection with 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 pr

involved in an investigation"; "[title district court was in the best position to weigh these factors") (internal quotations and citation omitted); Hardy, 697 Fed. App'x at 725 (2d Cir. 2017) (noting that courts have found that the following can defeat presumption of access: protection of ongoing inv

inical instructor at the Alpert Medical School of Brown University, and she has practiced psychology for

f identification" by showing a person in that position even a single photograph, much less a photo array or photo book. See, e.g., United States v. Hardy, No. 10 Cr. 1123 (JSR), 2011 WL 7782582 (S.D.N.Y. Jan. 25, 2011) ("Displaying a confirmatory photograph of a person the witness has indicated that

in jail.” HOUSE_OVERSIGHT_015414 And “Don’ t drop the soap” even made its way to the animated Family Guy. Meanwhile, reacting to the Tosh tirade, Julie Burton, president of the Women’ s Media Center, stated: “If free speech permits a comedian to suggest a woman in his audience should be gang-raped, then it

nto his cigar for a long time, but he never smoked it, he only sniffed it occasionally. “Everybody has their own Laurel HOUSE_OVERSIGHT_015374 and Hardy,” he mused. “A miniature Laurel and Hardy, one on each shoulder. Your little Oliver Hardy bawls you out--he says, ‘Well, this is a fine mess you've g

T 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 MAXWELL'S OBJECTIONS TO UNSEALING Sanford L. Bohrer Christine N. Walz 31 West 52nd Street New York, NY

nd these documents should be unsealed in their entirety. The objections mischaracterize the governing law, including the Second Circuit's ruling in Brown v. Maxwell, 929 F.3d 41 (2d. Cir. 2019); rely upon general "alleged countervailing interests" against disclosure that are not supported by the exten

judicial documents and that reflected sensitive information about cooperating witnesses and the government's investigative methods and techniques); Hardy v. Equitable Life Assurance Soc'y of United States, 697 F. App'x 723, 725 (2d Cir. 2017) (noting generally that protection of ongoing investigation

presumption applied to material introduced at trial, or in connection with 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 pr

nsure they "are not used to gratify private spite or promote public scandal" or "serve as reservoirs of libelous statements for press consumption." Brown, 929 F.3d at 51 (quoting Nixon v. Warner Commens, Inc., 435 U.S. 589, 598 (1978)). The Brown court held: "District courts should exercise the full

involved in an investigation"; "[t]tle district court was in the best position to weigh these factors") (internal quotations and citation omitted); Hardy, 697 Fed. App'x at 725 (2d Cir. 2017) (noting that courts have found that the following can defeat presumption of access: protection of ongoing inv