8
Shared Docs
5
Same-Page
11 / 8
Mentions
URT OF APPEALS FOR THE SECOND CIRCUIT Plaintiff-Appellee, v. GHISLAINE MAXWELL, Defendant, v. SHARON CHURCHER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, Intervenors-Appellants No. 18-2868 Appellee Maxwell's Motion to Reconsider and Vacate the Court's Order to Show Cau
N CHURCHER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, Intervenors-Appell
her interests can rise to the level of a compelling interest sufficient to overcome any presumption of right to access. See, e.g., United States v. Longueuil, 567 F. App'x 13, 16 (2d Cir. 2014) (holding that district court properly sealed contested documents "as they reflected sensitive information about
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
he integrity of criminal investigations and the privacy and safety of witnesses and suspects that are part of those investigations. United States v. Longueuil, 567 F. App'x 13, 16 (2d Cir. 2014) (holding that district court properly sealed contested documents "as they reflected sensitive information about
closure of these materials to permit Defendant to make application to the U.S. Court of Appeals for the Second Circuit for a more extended stay."); Brown v. Maxwell, 929 F.3d 41, 54 (2d. Cir. 2019) (recognizing likelihood of future appeals in this matter). 1. There are new, intervening and significan
fairness to the defendants, see W. at 602 n.14. In In re New York Times Co., 828 F.2d 110 (2d Cir. 1987), cited with approval in United States v. Longueuil, 567 Fed. App'x 13,16 (2d Cir. 2014), Judge Weinstein denied the media's motion to unseal papers filed in connection with an unsuccessful defense mo
Inc. 3992 Aviation Circle Fulton County Airport-Brown Field Atlanta, Georgia 30336 .......0s,1/.2,4ca
DE SORTIE A UTORISE • 3 Comeau Rd Pio • Pe de ,Hasa a ton SEE BLOCK S • 5 auk OrtielCounanuena • ea a Paaranuateaaae 1000 :t & Whitney Canada Longueuil, MarioNiNotin Blvd. Quebec MG 1A1 P.0.19000016693 .....................,.............c.-.... I Pan Re • N• 0 ana I Dobai • Idematai • • On -Oil
closure of these materials to permit Defendant to make application to the U.S. Court of Appeals for the Second Circuit for a more extended stay."); Brown v. Maxwell, 929 F.3d 41, 54 (2d. Cir. 2019) (recognizing likelihood of future appeals in this matter). 1. There are new, intervening and significan
fairness to the defendants, see id. at 602 n.14. In In re New York Times Co., 828 F.2d 110 (2d Cir. 1987), cited with approval in United States v. Longueuil, 567 Fed. App'x 13, 16 (2d Cir. 2014), Judge Weinstein denied the media's motion to unseal papers filed in connection with an unsuccessful defense m
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
Page: EFTA00017074 →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
Page: EFTA00017075 →criminal 4 EFTA00017078 --- PAGE BREAK --- casceamgQAR6nag'49kcnenbt•NeffFiWo*lieZt3&@f2V2f?an§ef61•9f 10 investigations. See United States v. Longueuil, 567 F.App'x 13, 16 (2d Cir. 2014) (finding it was not an abuse of discretion to allow continued sealing of discovery materials that were not judici
Page: EFTA00017079 →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
Page: EFTA00022965 →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
Page: EFTA00022967 →he integrity of criminal investigations and the privacy and safety of witnesses and suspects that are part of those investigations. United States v. Longueuil, 567 F. App'x 13, 16 (2d Cir. 2014) (holding that district court properly sealed contested documents "as they reflected sensitive information about
Page: EFTA00022968 →closure of these materials to permit Defendant to make application to the U.S. Court of Appeals for the Second Circuit for a more extended stay."); Brown v. Maxwell, 929 F.3d 41, 54 (2d. Cir. 2019) (recognizing likelihood of future appeals in this matter). 1. There are new, intervening and significan
Page: EFTA00021862 →fairness to the defendants, see id. at 602 n.14. In In reNew York Times Co., 828 F.2d 110 (2d Cir. 1987), cited with approval in United States v. Longueuil, 567 Fed. App'x 13,16 (2d Cir. 2014), Judge Weinstein denied the media's motion to unseal papers filed in connection with an unsuccessful defense mo
Page: EFTA00021866 →Entities connected to both Julie K. Brown and Longueuil

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
United States
LOCATION
Virginia Giuffre
PERSON
Bradley Edwards
PERSON
Colorado
LOCATION
Bradley Cooper
PERSONSouthern District
LOCATION
Harvey Weinstein
PERSON
Denver
LOCATION
Paul Cassell
PERSON
Cynthia Nixon
PERSON
David Boies
PERSON
Southern District of New York
ORGANIZATION
Anderson
PERSONSecond Circuit
ORGANIZATION
Russell Simmons
PERSON
The New York Times
ORGANIZATION