Epstein Secrets

mework or "higher values" in the First Amendment framework so demand. Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 124 (2d Cir. 2006); see also Unites States v. Wey, 256 F. Supp. 3d 355, 411 (S.D.N.Y. 2017) (Nathan, J.) (granting motion to seal evidentiary exhibits and finding that privacy interests "out

November 25,2020 Page 3 Here, that lower presumption is far outweighed by the significant privacy interests implicated by the materials at issue. See United States v. Amodeo, 71 F.3d 1044,1050 (2d Cir. 1995) ("[t]he privacy interests of innocent third parties ... should weigh heavily in a court's balancing equ

uments under seal if "countervailing factors" in the common law framework or "higher values" in the First Amendment framework so demand. Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 124 (2d Cir. 2006); see also Unites States v. Wey, 256 F. Supp. 3d 355, 411 (S.D.N.Y. 2017) (Nathan, J.) (granting motion

mework or "higher values" in the First Amendment framework so demand. Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 124 (2d Cir. 2006); see also Unites States v. Wey, 256 F. Supp. 3d 355, 411 (S.D.N.Y. 2017) (Nathan, J.) (granting motion to seal evidentiary exhibits and finding that privacy interests "out

November 25,2020 Page 3 Here, that lower presumption is far outweighed by the significant privacy interests implicated by the materials at issue. See United States v. Amodeo, 71 F.3d 1044,1050 (2d Cir. 1995) ("[t]he privacy interests of innocent third parties ... should weigh heavily in a court's balancing equ

uments under seal if "countervailing factors" in the common law framework or "higher values" in the First Amendment framework so demand. Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 124 (2d Cir. 2006); see also Unites States v. Wey, 256 F. Supp. 3d 355, 411 (S.D.N.Y. 2017) (Nathan, J.) (granting motion

ial function and useful in the judicial process," thereby qualifying as a "judicial document" for purposes of the first element of the Lugosch test. United States v. Amodeo ("Amodeo 1"), 44 F.3d 141, 145 (2d Cir. 1995). Second, the Court assumes that the common law presumption of access attaches, thereby satis

The Court's decision to adopt the Government's proposed redactions is guided by the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Under this test, the Court must: (i) determine whether the documents in question are "judicial documents;"

F.3d 110 (2d Cir. 2006) and narrowly tailored to protect the pre-trial privacy interests of alleged victims, anticipated witnesses, and non-parties. See United States v. Amodeo, 71 F.3d 1044, 1050-51 (2d Cir. 1995). The parties are hereby ORDERED to file the proposed redactions and accompanying exhibits on the p

he proposed redactions and requests to seal certain exhibits are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) and narrowly tailored to protect the pre-trial privacy interests of alleged victims, anticipated witnesses

ial function and useful in the judicial process," thereby qualifying as a "judicial document" for purposes of the first element of the Lugosch test. United States v. Amodeo ("Amodeo I"), 44 F.3d 141, 145 (2d Cir. 1995). Second, the Court assumes that the common law presumption of access attaches, thereby satis

The Court's decision to adopt the Government's proposed redactions is guided by the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Under this test, the Court must: (i) determine whether the documents in question are "judicial documents;"

redacted version this letter motion. The proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although this letter motion is a judicial document subject to the common law presumption of access, the pro

." Federal Rule of Civil Procedure 44(a)(1), in turn, permits proof of a domestic "official record" that is "otherwise admissible and is kept within the United States, any state, district, or commonwealth, or any territory" through EFTA00010106 --- PAGE BREAK --- Page 3 a copy attested by the officer with lega

redacted version this letter motion. The proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although this letter motion is a judicial document subject to the common law presumption of access, the pro

." Federal Rule of Civil Procedure 44(a)(1), in turn, permits proof of a domestic "official record" that is "otherwise admissible and is kept within the United States, any state, district, or commonwealth, or any territory" through EFTA00010112 --- PAGE BREAK --- Page 3 a copy attested by the officer with lega