Epstein Secrets

fessional relationships as well as matters concerning her private affairs." • March 17, 2016 (DE 66 at 9): At hearing on the Protective Order, Ms. McCawley stated "I can have the deposition of the defendant in this case and move this case forward. I will agree to their protective order. I just want tha

aration of Laura A. Menninger in Support of Ms. Maxwell's Reply In Support of Her Objection to Unsealing Sealed Material via ECF on the following: Sigrid S. McCawley Meredith Schultz Bows, $CHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale. FL 33301 Bradley J. Edwards Stan J. Potti

edaction of the item, and (c) whether the countervailing interests rebut the presumption of public access to the item." DE 1044 at 1. Plaintiff and the Miami Herald's responses improperly afford the highest level of presumption to discovery dispute documents, deny that any countervailing interests exist, and prote

. 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: LAURA A. MENNINGER 19 20 21 22 23 24 25 SOUTHERN DISTRICT REPORTERS, P.

on to compel defendant to answer deposition questions. Unseal subject to the caveat which I won't keep saying. 144. Plaintiff's declaration of Ms. McCawley in support of the motion. Unseal. 144-1. Exhibit 1. Page 21 of Ms. Maxwell's April 22, 2016 deposition. Unseal. 144-2. Additional pages of Ms. Ma

F.2d 110, 116 (2d Cir. 1987) (recognizing "defendants' fair trial rights" as an "appropriate" basis for sealing material). Lest there be any doubt, the Miami Herald's response to Ms. Maxwell's emergency motion to stay settles the matter. In opposing Ms. Maxwell's request, the Herald said: "The documents at issue

, said in a statement read by her lawyer, Sigrid McCawley, outside federal court. Two other women who have

ld Epstein accountable for his crimes,' who said she was forced to have sex with the financier in her 20s, said in a statement read by her lawyer, Sigrid McCawley, outside federal court. Two other women who have said they were abused by Mr. Epstein when they were teenagers, and watched the proceedings from t

rimes in New York a decade ago. Mr. Berman said his office had been "assisted by some excellent investigative journalists," an apparent reference to The Miami Herald's reporting from November. The indictment said that Mr. Epstein and his employees engaged in a sex-trafficking scheme, bringing dozens of vulnerable

United States District Court for the Sigrid S. McCawley Southern District of New York (smccawley@bsfllp

ore a seal is imposed."). At oral argument, neither the parties to the appeals nor the panel itself suggested the district court's opinion denying the Miami Herald's unseal motion misstated the right-to-access law. To the contrary the Opinion correctly summarized the law, and properly identified the leading case

nford L. Bohrer, Esq. Counsel for Plaintiff : BOIES SCHILLER & FLEXNER LLP, 401 E. Las Olas Boulevard, Suite 1200, Fort 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, 4

te 1200, Fort Lauderdale, FL 33301, By: Sigrid S. McCawley, Esq., Meredith L. Schultz, Esq., BOIES SCHILLER

seal the Summary Judgment Judicial Documents is Denied...444 VII. Conclusion...447 Third-party proposed intervenors The Miami Herald Media Company (the "Miami Herald") and investigative journalist for the Miami Herald Julie Brown ("Brown") (collectively, the "Intervenors"), have moved pursuant to Federal Rule of