Epstein Secrets

ery sealed filing on the district court docket. The district court denied the motion to unseal. The Miami Herald appealed, and this Court reversed. Brown v. Maxwell, 929 F.3d 41, 44-45 (2d Cir. 2019). The majority concluded that the district court erred in sealing the summary judgment materials. Id.

to answer numerous personal, sensitive, and allegedly incriminatory questions only after the plaintiff and the district court, through a stipulated Protective Order, guaranteed the confidentiality of her answers. As this Court has long recognized, and as this case shows, "witnesses might be expected frequently

18 EFTA00086659 TABLE OF AUTHORITIES Cases Benkovitch v. Gorilla, Inc., No. 2:15-ev-7806 (WJM), 2017 WL 4005452 (D.N.J. Sept. 12, 2017) 17 Brown v. Maxwell, 929 F.3d 41 (2d Ck 2019) 3, 6 Chambers v. NASCO, Inc., 510 U.S. 32 (1991) 17 Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D. 91

ial discovery material (including the two Maxwell depositions) with anyone else, including with the government and law enforcement. Faced with that Protective Order, the government issued a grand jury subpoena for Boies Schiller's file and instituted an ex parte proceeding before Chief Judge McMahon to modify t

2006 Subpoena to The Dalton School (return date 9/29/09) 9/26/2006 Acosta, Mulvihill, Sloman, Noto, Waters, L°urie' Stefin, Atkinson, Garcia, Brown, Boscovich, Martinez Villafaila Memo regarding changes to Child Explotation Statutes in Tide 18 16 10/19/2006 Subpoena to Individual #28 (retu

rview of AUSA Villafarla; and (c) participate fully in OPR's interview of AUSA Villafaiia. Disclosure shall be limited as set forth in the attached Protective Order. To the extent that AUSA Villafafla's May 10, 2019 Response to OPR's written questions and any drafts thereof disclosed any material that arguably