Intervenors Julie Brown and Miami Herald Media Co submit response to Defendant Ghislaine Maxwell’s Memo of Law in Support of
Objections to Unsealing Sealed Materials and to the objections raised in Ms. Maxwell’s November 18 letter regarding J. Doe 1
Ms . Maxwell’s Obections To The Unsealing Of The Second
Batch Of Documents Are Without Merit, And These Documents
Should Be unsealed .
A. Reliance on a Protective Order By a Party or Non-Party
C. Unsubstantiated Claims and Speculative Harms Regarding Ms. Maxwell’s Right to a Fair Jury Trial
D. Ms. Maxwell Fails to Provide Specific Objections That Could Justify Sealing.
II. MS. MAXWELL’S OBJECTIONS TO THE UNSEALING OF THE J. DOE 1
DEPOSITION HAVE ALREADY BEEN RULED UPON.
CONCLUSION
For all of the foregoing reasons, Intervenors respectfully request that this Court unseal sealed materials and their related submissions, as well as all docket entries that received no objection. Intervenors request that the J. Doe 1 transcript be released immediately
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