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

16) 9, 11, 14 Bernstein v. O'Reilly, Case No. 17-cv-9483 (April 3, 2018) 9 Carlson v. Geneva City Sch. Dist, 277 F.R.D. 90 (W.D.N.Y. 2011) 15 Condit v. Dunne, 225 F.R.D. 113 (S.D.N.Y. 2004) 15 E*Trade Fin. Corp. v. Deutsche Bank AG, 582 F. Supp. 2d 528 (S.D.N.Y. 2008) 9 Equal Emp's Opponunit

a sophmore (Elizabeth Brown's age) and loves IAA. She is a creative writer, and her parents were at the recent even that Rich and I attended at the Brown's house. Hope you are well! Take care. G Gayle E. Shaw Director of Special Gifts University at Buffalo Office of University Development 202 We

ft leasing division. According to Boeing executives, Mr. Welch had already committed to buying two 737's for corporate use, but mentioned to Mr. Condit that they still lacked the range of tradi- tional, smaller corporate jets. Boeing then set 100 engineers to work designing a 737 with the most mo

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

l notice, as Judge Nathan herself may have, of the widespread negative media publicity and speculation directed at Mr. Epstein and Ms. Maxwell. See Condit v. Dunne, 317 F. Supp. 2d 344, 358 (S.D.N.Y. 2004). We attach a compilation of such articles in EXHIBIT E. The Court also may take judicial notice