Epstein Secrets

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

d Dep't 1993) 11, 14 People v. Epstein, 89 A.D.3d 570, 933 N.Y.S.2d 239 (1st Dep't 2011) passim 4811.3721.9459v.2 3930033-000039 EFTA00805350 Press-Enterprise Co. v. Superior Court, 464 U.S. 501 (1984) Press-Enterprise Co. v. Superior Court, 478 U.S. 1 (1986) 13 11 Richmond Newspaper& Inc. v. Virginia, 4

THERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Ma rr a /.1 o hnson JANE DOES #1 AND #2, Petitioners, v. UNITED STATES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO PETITIONERS' MOTION TO USE CORRESPONDENCE TO PROVE VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT AND TO HAVE THEIR UNREDACTED PLEADINGS

s to the sealed documents and transcripts here could easily kill many reputations. This overriding interest is, I believe, of a higher value under [Press-Enterprise Co. v. Superior Court, 464 U.S. 501 (1984)] so as to warrant sealing, and provides good cause under the common-law access balancing test to preclude di

n to Use Correspondence to Prove Violations of the Crime Victims' Rights Act and to Have Their Unredacted Pleadings Unsealed (DE51). As explained in the United States' Response to Petitioners' Motion for Finding of Violations of the Crime Victims Rights Act (DE48), and Petitioners' Motion to Have Their Facts Accep

to the sealed documents and transcripts here could easily kill many re utations. This overriding interest is, I believe, of a higher value under [ Press-Enterprise Co. I Superior Court , 464 U.S. 501 (1984)] so as to warrant sealing, and provides good cause under the common-law access balancing test to preclude di

gly expects this to happen. Congress adopted the CVRA with the express goal of making the new law "a formula [*855] for success" and a "model for our States." 111 Congress clearly wants the new law aggressively implemented, thereby avoiding the need for further legislative action or even, possibly, a fede

ge, 29 Okla. L. Rev. 803 (1976). 204 448 U.S. 555 (1980). 205 Gannett Co. v. DePasquale, 443 U.S. 368, 380 (1979) (internal citation omitted). 206 Press-Enterprise Co. v. Superior Court, 464 U.S. 501, 509 (1984). 207 Gannett Co., 443 U.S. at 428 (Blackmun, J., concurring in part and dissenting in part). 208 Richmo