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t seal the entire court record, as happened 4 EFTA00600018 Case 9:08-cv-80736-KAM Document 295 Entered on FLSD Docket 01/26/2015 Page 5 of 18 in Brown and Wilson. Instead, because we are seeking only that the Court temporarily seal discrete documents rather than complete pleadings or an entire doc
s already been permitted substantial access to the contents of the records." Newman v. Graddic, 696 F.2d 796, 803 (11th Cir. 1983) (citing Nixon v. Warner Communications, Inc., 435 U.S. at 598-603 & n. II). "Although difficult to define in absolute terms," the term `good cause' "generally signifies a sound basis or
t seal the entire court record, as happened 4 EFTA00210720 Case 9:08-cv-80736-KAM Document 295 Entered on FLSD Docket 01/26/2015 Page 5 of 18 in Brown and Wilson. Instead, because we are seeking only that the Court temporarily seal discrete documents rather than complete pleadings or an entire doc
e press has already been permitted substantial access to the contents of the records." Graddic, 696 F.2d 796, 803 (11th Cir. 1983) (citing Nixonl. Warner Communications, Inc., 435 U.S. at 598-603 & n. II). "Although difficult to define in absolute terms," the term `good cause' "generally signifies a sound basis or
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
in deciding whether to unseal materials it was important to give weight to the impact on a criminal defendant's right to a fair trial. In Nixon v. Warner Communications, Inc., 435 U.S. 589 (1978), a number of media moved the district court to release audio tapes admitted into evidence in the trial of four of Preside
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
in deciding whether to unseal materials it was important to give weight to the impact on a criminal defendant's right to a fair trial. In Nixon v. Warner Communications, Inc., 435 U.S. 589 (1978), a number of media moved the district court to release audio tapes admitted into evidence in the trial of four of Preside
EFTA00582791 circumstances or particularized needs@ standard because we are not asking that the Court seal the entire court record, as happened in Brown and Wilson. Instead, because we are seeking only that the Court temporarily seal discrete documents rather than complete pleadings or an entire doc
s already been permitted substantial access to the contents of the records.@ Newman v. Graddic, 696 F.2d 796, 803 (11th Cir. 1983) (citing Nixon v. Warner Communications, Inc., 435 U.S. at 598-603 & n. 11). AAlthough difficult to define in absolute terms,@ the term >good cause= Agenerally signifies a sound basis or
Entities connected to both Julie K. Brown and Warner Communications

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Ghislaine Maxwell
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United States
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Alan Dershowitz
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Virginia Giuffre
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Prince Charles
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Cynthia Nixon
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David Boies
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Anderson
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