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e on the Judiciary, US. House of Representatives, For an Qrder Authorizilig the Release of Certain Grand Jury Materials, Committee oh the Judiciary, United States House of Representatives v. US. Department of Justice, No. 19-5288 (D.C. Cir. March 20, 2020) (ordering the Trump administration to provide the Hous
ntly, public access to trials acts as an important check, akin in purpose to the other checks and balances i that infuse our system of government.”); Globe Newspaper Co. v. Superior Courtfor Norfolk County, 457 U.S. 596, 606 (1982) (“the right of access to criminal trials plays a particularly significant role in the f
MEMORANDUM OF LAW IN SUPPORT OF MOTION TO UNSEAL APPELLATE BRIEFS DAVIS WRIGHT TREMAINE LIP Robert D. Balin John M. Browning 1251 Avenue of the Americas, 21st Floor New York, New York 10020-1104 Telephone: (212) 603-6410 Counsel for Non-Party Movant NYP Holdings, Inc. 4811.3721.94S9v.2 3930033-00
6 N.Y.S.3d 19 (1st Dep't 2015) 10 Danco Labs., Ltd v. Chem. Works of Gideon Richter, Ltd, 274 A.D.2d 1, 711 N.Y.S.2d 419 (1st Dep't 2000) 11, 13 Globe Newspaper Co. v. Superior Court, 457 U.S. 596 (1982) 11, 13 In re Application of National Broad Co., 635 F.2d 945 (2d Cir. 1980) 11, 13 In re Associated Pres
ivil case moved for permissive intervention for purposes of unsealing record in previous unrelated case against defendant brought by another party. The United States District Court for the Northern District of Georgia, No. 1:87-CV-1165-RHEL Robert H. Hall, J., denied motion as untimely. Plaintiff appealed. The C
nterest, and is narrowly tailored to b..) that interest." ' Id., at 1571 (quoting Newman v. Graddick, 696 F.2d 796, 802 (I I th Cir.1983) (quoting Globe Newspaper Co. v. Superior Court, 457 U.S. 596, 606-07. 102 S.Ct. 2613, 2619-20, 73 L.Ed.2d 248 (1982))) (emphasis added). [2] It is immaterial whether the seal
men who may have civil damages claims against Mr. Epstein. The U.S. Attorney's Office and the Federal Bureau of Investigation (jointly referred to as the "United States") have conducted an investigation of Jeffrey Epstein regarding his solicitation of minor females in Palm Beach County to engage in prostitution. Mr.
Page: HOUSE_OVERSIGHT_013323 →l master regarding handling numerous expected civil claims against Epstein. The letter reads in pertinent part, "The undersigned, as counsel for the United States of America and Jeffrey Epstein, jointly write to you to provide information relevant to your service as a Special Master in the selection of an attorney to repr
Page: HOUSE_OVERSIGHT_013323 →plead a claim for punitive damages, the claimant must show a “reasonable basis” for the recovery of such damages. See Fla.R.Civ-P. 1.190(f); see also Globe Newspaper Co. v. King, 658 So.2d 518, 520 (Fla. 1995). The showing required to amend is minimal. As stated in State of Wis. Inv. v. Plantation Square Assoc., 761 F
Page: HOUSE_OVERSIGHT_013396 →n a sealed The right of access is an affirmative, enforceable public right, and the standing of the press to enforce it is well settled. See, e.g., Globe Newspaper Co. v. Superior Court, 457 U.S. 596, 609 n.25 (1982); Hanford Courant Co. v. Pellegrino, 380 F.3d 83, 91 (2d Cir. 2004). EFTA00017095 --- PAGE BREAK
Page: EFTA00017095 →e no history of openness, the mere "logic" of public access is a sufficient basis for the First Amendment right. See, e.g., Suarez, 880 F.2d at 631; United States v. Index Newspapers LLC, 766 F.3d 1072, 1094 (9th Cir. 2014) ("logic alone, even without experience, may be enough to establish the [First Amendment]
Page: EFTA00017098 →Entities connected to both United States and Globe Newspaper Co.

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Alexander Acosta
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSON
New York
LOCATION
Marc Rich
PERSON
Donald Trump
PERSON
Bill Clinton
PERSONJack Goldberger
PERSON
Julie K. Brown
PERSON
Virginia Giuffre
PERSON
New York City
LOCATIONMartin Weinberg
PERSON