Epstein Secrets

/2020, 2913550, Page48 of 74 Respectfully submitted, s/ Adam Mueller Ty Gee Adam Mueller HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 Tel 303.831.7364 Fax 303.832.2628 [email protected] [email protected] Counsel for Defendant-Appellant Ghislaine Maxwell 42 EFTA0007

terial should remain sealed to protect Ms. Maxwell's right to a fair trial by an impartial jury. U.S. CONST. amends. V, VI. The decision in Nixon a Warner Communications, Inc., 435 U.S. 589 (1978) shows why. In that case, members of the media moved the district court to release audio tapes admitted into evidence in the tr

lt Lake City, UT 84112, By: Paul G. Cassell, Esq. Counsel for Defendant Ghislaine Maxwell: HADDON, MORGAN AND FOREMAN, P.C., 150 East 10th Avenue, Denver, CO 80203, By: Laura A. Menninger, Esq., Jeffrey S. Pagliuca, Esq., Ty Gee, Esq. Counsel for Intervenor Michael Cemovich: RANDAZZA LEGAL GROUP, PLL

uments may be kept under seal if ... `higher values' in the First Amendment framework so demand."). Further, as the Supreme Court noted in Nixon v. Warner Communications, Inc., 435 U.S. at 589, 98 S.Ct. 1306, "courts have the power to insure that their records are not used to gratify private WESTLAW © 2018 Thomson Reuters

s District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, P.0 Ty Gee 150 East 10th Avenue Denver, Colorado 80203 ni 303.831.7364 rx 303.832.2628 www.hmtlaw.com tgeefghmflaw.com Re: Reconsideration of the Court's July 23 Ruling Giuffre v. Ghi

in deciding whether to unseal materials it was important to give weight to the impact on a criminal defendant's right to a fair trial. In Nixon v. Warner Communications, Inc., 435 U.S. 589 (1978), a number of media moved the district court to release audio tapes admitted into evidence in the trial of four of President Ni