Epstein Secrets

hrer ([email protected]) Andrew G. Celli ([email protected]) David Lebowitz ([email protected]) Jay M. Wolman ([email protected]) s/ Nicole Simmons 26 EFTA00791895

at the district court (or the appellees) unjustifiably delayed resolution of the unseal motions and its abuse of discretion in failing to adhere to the Second Circuit's "clear[]"3 precedent. We respectfully submit that neither conclusion warrants the extraordinary action being contemplated by the panel. A. The dist

e 6th Floor New York, NY 10036 Jay M. Wolman Marc J. Randazza RANDAZZA LEGAL GROUP, PLLC 100 Pearl Street, 14th Floor Iarford m CT 06103 /s/ Nicole Simmons Nicole Simmons 22 EFTA00074985 CaesR294114034B9(1AffenDbOtaneRt3W202( ifi6DOWII/Reglabef140f 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT

re "unjustified obstacles" or that the public will never have access to these documents -- reflect unjustified criticisms of the Protocol itself and the Second Circuit's decision in Brown, both of which fairly outline the legal process for parties and Non-Parties alike to be heard with respect to unsealing. Notably,

s Objections to Unsealing Docket Entries 143, 173, and 199 and to Unsealing Docket Entries 164 and 230 at This Time. via ECF on the following: Is/ Nicole Simmons Nicole Simmons 2 EFTA00075006 Casqakigiegota3R424Pleabigr§eili1W041413t5W1Vgagteaf128If 17 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF N

19) (emphasis supplied; footnote omitted; quoting United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995) ("Amodeo r')). Amodeo I, the inception of the Second Circuit's principle that a file stamp is not a judicial-document talisman, is instructive. There an appointed Court Officer tasked parties; DE 204-1 referenc

y 29, 2020, I filed this Notice of Appeal with the Clerk of Court through CM/ECF, which will send notice of the filing to all parties of record. hi Nicole Simmons 2 EFTA00076390 Case Gaga4.407741333-IDARn-Offiuhiefle3MOQIXD, Filki5B33fface9:4191;91 of 4 App.-0783 United States District Court Southern Dis

Cr. 330 (AJN) (the "Criminal Action"). The information implicates Ms. Maxwell's right to due process and fairness in this civil action and affects the Second Circuit's review of the Court's unsealing order of July 23, 2020. Additionally, the information implicates her rights as a criminal defendant guaranteed unde