Epstein Secrets

n electronically mailed to: EFTA00078636 David Boies, II [email protected] NYC Managing Clerk@bsfIlp

110 (2d Cir. 2006) (Signed by Judge Alison J. Nathan on 11/19/21)(jw) 1:20-cr-00330-AJN-1 Notice has been electronically mailed to: EFTA00078636 David Boies, II [email protected] NYC Managing [email protected] Patrick J. Smith patrick.smith@smithvillazoccom suzanne.kowalski@smithvillazoccom Jeffrey S.

et on or before November 22, 2021, and to justify any requested redactions by reference to the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) (Signed by Judge Alison J. Nathan on 11/19/21)(jw) 1:20-cr-00330-AJN-1 Notice has been elec

, on the brief), Haddon, Morgan and Foreman, P.C., Denver, CO, for Defendant-Appellee Ghislaine Maxwell. Paul G. Cassell (Sigrid S. McCawley, Boies Schiller Flexner LLP, Ft. Lauderdale, FL, on the brief), S.J Quinney College of Law, University of Uta • T, for Plaintiff-Appellee Andrew G. C

narrowly tailored to achieve that aim."I3 12 Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 121 (2d Cir. 2006). We observe that our holding in Lugosch relies on the general principle that parties may "be assumed to have supported their papers with admissible evidence and non-frivolous arguments."

" Id. at 122. Insofar as a district court has, through striking a filing, specifically found that assumption inapplicable, the categorical rule in Lugosch may not apply. See notes 42-43 and accompanying text, post. 13 Id. at 124. Examples of such countervailing values may include, depending on the c

), Haddon, Morgan and Foreman, P.C., Denver, CO, for Defendant-Appellee Ghislaine Maxwell. 3 EFTA00092310 PAUL G. CASSELL (Sigrid S. McCawley, Boies Schiller Flexner LLP, Ft. Lauderdale, FL, on the brief), S.J Quinney College of Law, University of Utah, Salt Lake City, UT, for Plaintiff-Appell

g order is narrowly tailored to achieve that aim."13 " Bernstein v. Bernstein Litowitz Berger & Grossmann LLP, 814 F.3d 132, 139 (2d Cir. 2016). 12 Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 121 (2d Cir. 2006). We observe that our holding in Lugosch relies on the general principle that parties ma

ann LLP, 814 F.3d 132, 139 (2d Cir. 2016). 12 Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 121 (2d Cir. 2006). We observe that our holding in Lugosch relies on the general principle that parties may "be assumed to have supported their papers with admissible evidence and non- frivolous arguments."

effrey Epstein sexually abusing her. The law firm Boies Schiller Flexner LLP (BSF) represented in the d

to a court's ruling, Second Circuit precedent creates a strong presumption that they will be made public notwithstanding any protective order. See Lugosch, 435 F.3d at 126. These are not remote or theoretical possibilities. Each of them predictably came to pass in this case. See Brown, 929 F.3d at 48

effrey Epstein sexually abusing her. The law firm Boies Schiller Flexner LLP (BSF) represented in the d

to a court's ruling, Second Circuit precedent creates a strong presumption that they will be made public notwithstanding any protective order. See Lugosch, 435 F.3d at 126. These are not remote or theoretical possibilities. Each of them predictably came to pass in this case. See Brown, 929 F.3d at 48

effrey Epstein sexually abusing her. The law firm Boies Schiller Flexner LLP (BSF) represented in the d

to a court's ruling, Second Circuit precedent creates a strong presumption that they will be made public notwithstanding any protective order. See Lugosch, 435 F.3d at 126. These are not remote or theoretical possibilities. Each of them predictably came to pass in this case. See Brown, 929 F.3d at 48

Defendant. x 9 New York, N.Y. 10 July 23, 2020 11:30 a.m. 11 Before: 12 HON. LORETTA A. PRESKA, 13 District Judge 14 APPEARANCES 15 BOIES, SCHILLER & FLEXNER, LLP 16 Attorney for Plaintiff BY: SIGRID S. MCCAWLEY 17 HADDON, MORGAN, AND FOREMAN, P.C. 18 Attorney for Defendant BY:

e minimally redacted material was subject to a "strong presumption" of access under the First Amendment and the common law. Id. at 47 & n.12 (citing Lugosch, 435 F.3d at 121-22). The deposition material at issue here, however, was not submitted to the district court in connection with summary judgment

effrey Epstein sexually abusing her. The law firm Boies Schiller Flexner LLP (BSF) represented in the d

to a court's ruling, Second Circuit precedent creates a strong presumption that they will be made public notwithstanding any protective order. See Lugosch, 435 F.3d at 126. These are not remote or theoretical possibilities. Each of them predictably came to pass in this case. See Brown, 929 F.3d at 48

effrey Epstein sexually abusing her. The law firm Boies Schiller Flexner LLP (BSF) represented in the d

to a court's ruling, Second Circuit precedent creates a strong presumption that they will be made public notwithstanding any protective order. See Lugosch, 435 F.3d at 126. These are not remote or theoretical possibilities. Each of them predictably came to pass in this case. See Brown, 929 F.3d at 48

Lauderdale, FL 33301, By: Sigrid S. McCawley, Esq., Meredith L. Schultz, Esq., BOIES SCHILLER & FLEXNER LLP, 333 Main Street, Armonk, NY 10504, By: David Boies, Esq., EDWARDS POTTINGLER LLC, 425 North Andrews Avenue, Suite 2, Fort Lauderdale, FL 33301, By: Bradley J. Edwards, Esq., S.J. QUINNEY COLLEGE OF

LP, 333 Main Street, Armonk, NY 10504, By: David Boies, Esq., EDWARDS POTTINGLER LLC, 425 North Andrews

008) (finding that where classified information presented at trial, if disclosed, would jeopardize national security weighed against public access); Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) (existence of confidentiality order alone did not defeat presumption of public access); Hanf