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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 Response to Order to Show Cause EFTA00794214 Appellee Ghisl
N CHURCHER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, Intervenors-Appell
c disclosure of any sealed or redacted summary judgment materials. The OTSC is, however, incomplete because the dozens of individuals who relied on the Protective Order had no notice of the Order and have had no opportunity to respond. We interpose the following general objections: 1. All sealed and redacted summa
girl was asked about her abortions, and her parents, who were Catholic and knew nothing about the abortions, were also deposed and questioned.” See Julie Brown, “Perversion of Justice: Cops Worked to Put a Serial Sex Abuser in Prison. Prosecutors Worked to Cut Him a Break,” Miami Herald, Nov. 28, 2018.
ns, were also deposed and questioned.” See Julie Brown, “Perversion of Justice: Cops Worked to Put a Se
d by a Protective Order entered by the Court. If [the victim] would like to review the Agreement, please let me know, and I will forward a copy of the Protective Order for her signature. The government shared draft versions of the September letter with Epstein’s counsel and responded to criticism of the content o
ject matter is traditionally considered private rather than public. Cases that cite this hcadnote Attorneys and Law Firms Counsel for Interveners Julie Brown & Miami Herald Media Company: HOLLAND & KNIGHT LLP, 31 West 52nd Street, New York, NY 10019, By: Christine N. Walz, Esq., Sanford L. Bohrer, Esq.
Page: EFTA00020552 →Third-party proposed intervenors The Miami Herald Media Company (the "Miami Herald") and investigative journalist for the Miami Herald Julie Brown ("Brown") (collectively, the "Intervenors"), have moved pursuant to Federal Rule of Civil Procedure 24 to intervene in this defamation action brought by pl
Page: EFTA00020553 →mmon law right of access, or of the more robust First Amendment right to access certain judicial documents. Id. at 119-20. It is a given accepted by the Protective Order that the trial and all trial documents are accessible and public absent special circumstances. *8 1121 II3IUnder the common law approach, once a do
Page: EFTA00020562 →Entities connected to both Julie K. Brown and the Protective Order

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Prince Andrew
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Alan Dershowitz
PERSON
Virginia Giuffre
PERSON
Scarlett Johansson
PERSON
Woody Allen
PERSON
Bradley Edwards
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATIONFBI
ORGANIZATION
Lesley Groff
PERSON
Supreme Court
ORGANIZATION
Barry Diller
PERSON
Kenneth Marra
PERSONJane Doe
PERSON