EFTA00017074.pdf

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pdf

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data-set-8

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Extracted text

casgamge26143R-ficsarnecobalrgefiFiW044136§fgheatmbefilth 10 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
Virginia L. Giuffre, 
Plaintiff, 
v. 
Ghislaine Maxwell, 
Defendant. 
Case No.: 15-cv-07433-RWS 
INTERVENORS' JULIE BROWN AND MIAMI HERALD MEDIA CO.'S 
RESPONSE TO MAXWELL'S OBJECTIONS TO UNSEALING 
Sanford L. Bohrer 
Christine N. Walz 
31 West 52nd Street 
New York, NY 10019 
Telephone: 212.513.3200 
Fax: 212.385.9010 
Attorneys for Intervenors 
Julie Brown and Miami Herald Media Company 
EFTA00017074


casQac,./g%261'43g-ceg‘FenbegrrieRFA004lieif36643026'act6@f218f 10 
Pursuant to this Court's Order and protocol for Unsealing Decided Motions, Intervenors 
Julie Brown and Miami Herald Media Co. ("Miami Herald") respectfully submit this response to 
Ms. Maxwell's Memorandum Brief in Support of Her Objections to Unsealing Sealed Materials 
(Dkt. 1057) ("the Objections")} 
ARGUMENT 
Ms. Maxwell's objections to the unsealing of Dkt. Entries 143, 164, 172, 199, and 230 (and 
related submissions) are entirely without merit, and these documents should be unsealed in their 
entirety. The objections mischaracterize the governing law, including the Second Circuit's ruling 
in Brown v. Maxwell, 929 F.3d 41 (2d. Cir. 2019); rely upon general "alleged countervailing 
interests" against disclosure that are not supported by the extensive body of case law addressing 
whether a judicial document may be sealed by the Court; and assert unsubstantiated, generalized, 
and speculative harms based on the alleged countervailing interests that are insufficient to 
outweigh the presumption of access to these judicial documents. 
As set forth in detail below, there is no basis identified in the Objections for the Court to 
continue sealing Dkt. Entries 143, 164, 172, 199, and 230 (and related docket entries identified by 
Ms. Maxwell). 
I. 
Ms. Maxwell Mischaracterizes Brown v. Maxwell. 
Ms. Maxwell's filing selectively quotes from the Second Circuit's ruling in Brown v.…

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