PLAINTIFF’S BRIEF IN OPPOSITION TO MAXWELL’S OBJECTIONS TO
UNSEALING SEALED MATERIALS RELATED TO DOCKET ENTRIES
231, 279, 315, 320, & 335
PRELIMINARY STATEMENT
Argument
It is settled that there is a common law right to public access to judicial document
Rather than raising specific reasons that specific portions of these judicial documents should remain under seal, Maxwell instead submits a chart with the same generic “Countervailing Interests” this Court has already rejected, and asserts 2 vague arguments in favor of sealing.
For the reasons set forth below, the Court should reject each of Maxwell’s recycled arguments as meritless and contrary to how this Court and the Second Circuit have already ruled, and order the materials published with minimal redactions forthwith.
I. Maxwell’s Reliance on the Protective Order, if Any, Does Not Justify Sealing Her July 2016 Deposition Transcript.
II. Maxwell’s Argument Regarding Third-Party Reliance is Meritless.
III. Maxwell’s Argument About Her Right to a Fair Criminal Trial Was Raised and Rejected on Appeal
V. Maxwell’s Argument Concerning Potential Evidence at Her Criminal Trial Was Raised on Appeal and is Irrelevant to the Instant Inquiry.
V. The Court Should Not Release Plaintiff’s Medical Records.
Conclusion
For the foregoing reasons the Court should overrule Maxwells objections
Exhibit A
Plaintiff’s Position on Docket Entries 231, 279, 315, 320, & 335
Exhibit A
Plaintiff’s Position on Docket Entries 231, 279, 315, 320, & 335
Exhibit A
Plaintiff’s Position on Docket Entries 231, 279, 315, 320, & 335
Exhibit A
Plaintiff’s Position on Docket Entries 231, 279, 315, 320, & 335
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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