UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ------------------------ ---------x VIRGINIA L. GUIFFRE, Plaintiff, Case No.: 15-cv-7433 (RWS) -againstREPLY TO PLAINTIFF'S OPPOSITION TO MOTION TO INTERVENE AND UNSEAL GHISLAINE MAXWELL, Defendant. Movant Mike Cemovich hereby files his reply to Plaintiff's Response in Opposition to Motion to Intervene (Docket No. 589) (hereinafter the "Opposition"). Plaintiff ("Plaintiff' or a') Motion to Intervene and Unseal with invective and responds to Mr. Cemovich's accusations, but presents no legal reason for the Court to set aside the First Amendment's mandate that court proceedings, at this stage, be open to the public. In fact, has not even provided a basis to overcome the common law presumption of openness in judicial proceedings. instead of making a convincing argument about the law or the facts, has unfortunately chosen to concoct a conspiracy theories, ulterior motives, and personal vendettas. tale of Plaintiff's arguments are unsupported by law or fact. One week after Cemovich sought to intervene and unseal the summary judgment pleadings, counsel for Plaintiff filed yet another action in this District against Defendant Ghislaine Maxwell ("Maxwell"), as well as Jeffrey Epstein, based on allegations similar to those in this case. See Jane Doe 43 v. Jeffrey Epstein, el at, Case No. 1:17-cv-006 I 6-JGK (S.D.N.Y. Jan. 26, 2017) (complaint). Maxwell has now been accused of running or being involved in a child sex trafficking ring in multiple lawsuits. Maxwell's involvement in sex trafficking is newsworthy on its face. Indeed, the Daily Mail published an article about the most-recent lawsuit. See Gould, =, "EXCLUSIVE: Pedophile Jeffrey Epstein is accused of luring an 1 EFTA02802025