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Pursuant to Rule 24 of the Federal Rules of Civil Procedure, the Miami Herald Media
Company (the "Miami Herald"), and Julie Brown, investigative journalist for the Miami Herald
("Julie Brown" and together with Miami Herald, the "Intervenors"), respectfully submit this
memorandum of law in support of their motion to intervene and unseal all of the documents in the
above-captioned action that have been filed under seal or redacted. These judicial documents are
germane to the Miami Herald's ongoing coverage of dozens of underage minors who were victims
of Jeffrey Epstein, the South Florida financier who pleaded guilty in 2008 to solicitation of minors for prostitution and was suspected of involvement in a larger sex-trafficking organization. These documents are presumptively public, under both the common law and the First Amendment to the
United States Constitution, but have been sealed pursuant to an improvidently granted protective
order (ECF No. 62) (the "Protective Order") that allowed the parties to the above-caption actions
("Parties") to designate information as confidential without the particularized judicial scrutiny
required by the law prior to sealing. Though two previous motions to unseal have been denied,
the reasoning underlying the denial the imminence of trial, and potential impact on a jury is no
longer relevant because the case has been settled.