Case 1:15-cv-07433-LAP Document 1111 Filed 09/01/20 Page 1 of 14

Case 1:15-cv-07433-LAP Document 1111 Filed 09/01/20 Page 1 of 14 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-LAP THE GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' MEMORANDUM OF LAW IN SUPPORT OF EX PARTE MOTION TO INTERVENE AND FOR CONFIDENTIAL ACCESS TO JUDICIAL RECORDS AND DISCOVERY DOCUMENTS The Government of the United States Virgin Islands (the "USVI") moves to intervene in this action for the limited purpose of obtaining confidential access to both: (a) all sealed documents related to the parties' motions for summary judgment [ECF No. 540 to 543, 586 to 586-3, 620 to 621, and 872]; and (b) all unified discovery deposition transcripts and exhibits thereto. The USVI seeks to modify the Protective Order [ECF No. 62] solely to be granted confidential access to these materials, and, if granted access, agrees to be bound by the Protective Order. The USVI seeks confidential access to th