Epstein Secrets

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

e. The absence of a response, however, does not end the analysis. Although the Court's Protocol requires consideration of objections from the other Non-Parties yet to be noticed, the Court could (and should) determine, based on the circumstances of the Sealed Materials selected here, that the items are appr

to place Plaintiff's submission into context. DE 153 is Plaintiff's reply which, again quotes from Ms. Maxwell's deposition and references numerous Non-Parties. DE 153-1 contains 7 exhibits. Exhibit I is a portion of Ms. Maxwell's deposition. Exhibit 2 contains a "Flight Log Summary Chart" prepared by Plain

ls for the Second Circuit —against— GHISLAINE MAXWELL, SHARON CHURCHER, JEFFREY EPSTEIN, PlaintiffiAppellee, Defendant-Appellant, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNOVICH MEDIA Intervenors. ON APPEAL FROM THE UNITED STATES DISTRICT COU

ellee, Defendant-Appellant, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, ALAN M. DERSHOWITZ,

week per Non-Party to agree to the excerpts to send to them for review. But on balance we agree that having a sense of the number of participating Non-Parties will aid the Court in conducting future proceedings, we have agreed to Plaintiff's suggestion on that front. The parties can submit a proposed modif

roviding the Court with a list of broad and vague categories of reasons for maintaining nearly all of the motion papers in this matter under seal); Brown v. Maxwell, No. 18-2868, Dkt. 149 (2d Cir. Mar. 19, 2019) (listing in a cursory fashion several reasons that the summary judgment materials should r

ause only Doe 1 and Doe 2 have received notice of potential sealing thus far, and because the first five motions contain the names of various other Non-Parties, Maxwell contends in her objection that the Court cannot unseal any of the first five motions or their related docket entries until each Non-Party

t the public will never have access to these documents -- reflect unjustified criticisms of the Protocol itself and the Second Circuit's decision in Brown, both of which fairly outline the legal process for parties and Non-Parties alike to be heard with respect to unsealing. Notably, many of the docum

f the judicial function," "not considered a judicial document" and enjoys "no presumption of public access."). Further, in addition to Doe 1, other Non-Parties are included in DE's 185-3, 185-11, 185- 14 and 185-15 each of whom has not yet been notified or had the opportunity to object under this Court's Pr