giuffre-maxwell
gov.uscourts.nysd.447706.1328.22
22 pg
…Surveillance t niques, procedures, an (2)(h)(1) Identity of victim of sexual battery, lewd and
inventory of law enforcement resources, policies or ascivious offense upon a person less than 16 years old, child abuse,
to mobilization, deployment or tactical…
giuffre-maxwell
gov.uscourts.nysd.447706.41.5
18 pg
…abuse.
4. CONFIDENTIAL information shall not be disclosed or used for any purpose
except the preparation and trial of this case and any related matter, including
but not limited to, investigations by law enforcement.
5. CONFIDENTIAL documents, materials, and/or…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.4_1
4 pg
…to law enforcement records involving juveniles is protected by
C.R.S. 19-1-301, et. seq., as "[t]he disclosure of sensitive information carries the risk of
stigmatizing children." C.R.S. 19-1-302. Accordingly, Colorado law protects…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.4
23 pg
…abuse.
4. CONFIDENTIAL information shall not be disclosed or used for any purpose
except the preparation and trial of this case and any related matter, including
but not limited to, investigations by law enforcement.
5. CONFIDENTIAL documents, materials, and/or…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.0_2
65 pg
…Second set of Requests for Production on April 14. Those Requests
primarily concerned police reports about Plaintiff’s various contacts with law enforcement and
how the defense was able to obtain those publicly-available documents (RFP’s 1-5, 19)…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.1_1
13 pg
…to law enforcement records involving juveniles is protected by C.R.S. 19-1-301, et. seq.,
because "[t]he disclosure of sensitive information carries the risk of stigmatizing children." C.R.S.
19-1-302. Accordingly, Colorado law protects…
giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…cf. United States v.
Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995) (noting that law enforcement “may be heavily reliant
upon the voluntary cooperation of persons who may want or need confidentiality . . . [i]f that
confidentiality cannot be assured…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…of civil disputes. 594 F.2d at 295–96. And the Second Circuit there
found that true even in the face of “the public interest in obtaining all relevant evidence required
for law enforcement purposes,” id. at 296, arguably a…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…464 U.S. 501, 510 (1984); the protection of attorney‐client
privilege, Lugosch, 435 F.3d at 125; “the danger of impairing law enforcement or
judicial efficiency,” SEC. v. TheStreet.Com, 273 F.3d 222, 232 (2d Cir. 2001); and…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.31
13 pg
…privileges concerning obtaining or receiving 'local police[] findings or opinions’ and ‘statements
1
Case 1:15-cv-07433-LAP Document 1328-31 Filed 01/05/24 Page 3 of 13
made by law enforcement or any state attorney.’” (Br…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.16
22 pg
…executed schemes designed to recruit young females; and ensured that all
participants of the Defendants' sex tafficking scherre acted in certain specific
ways in order to advance the purposes of the scheme and conceal it from law
enforcement.
16. Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…464 U.S. 501, 510 (1984); the protection of attorney‐client
privilege, Lugosch, 435 F.3d at 125; “the danger of impairing law enforcement or
judicial efficiency,” SEC. v. TheStreet.Com, 273 F.3d 222, 232 (2d Cir. 2001); and…
giuffre-maxwell
gov.uscourts.nysd.447706.936.0
21 pg
…the Palm Beach state attorney, the FBI and the U.S. Attorney's Office, the negotiations between
those law enforcement agencies and Mr. Epstein's legal defense team, and the ultimate decision
by the U.S. Attorney's Office to…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.11
13 pg
…privileges concerning obtaining or receiving 'local police[] findings or opinions’ and ‘statements
1
Case 1:15-cv-07433-LAP Document 1219-11 Filed 07/15/21 Page 3 of 13
made by law enforcement or any state attorney.’” (Br…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…Ederi.
3. All Documents containing communications with Jason Richards.
4. All Documents containing communications with law
enforcement agency concerning Virginia Roberts.
5. All Documents reflecting any payment of any money to Virginia
Roberts.
…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…one of the largest and
17 most significant pieces to us are the assertions by plaintiff
18 that her own communications with law enforcement are somehow
19 protected by --
20 THE COURT: I'm prepared to deal with that.
21…
giuffre-maxwell
gov.uscourts.nysd.447706.40.0
8 pg
…the Designating Party; (e) pursuant to Order of the Court; or (f) for
purposes of law enforcement.”
6
As addressed above, Ms. Giuffre proposed revisions to ensure that the Protective Order is
fair and limited in scope so as…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…undue
harassment serving no admissible purpose.
25. Any Documents containing any Communications You have had with any law enforcement
agency.
RESPONSE:
21
In addition to the Preliminary Statement and General Objections, Ransome objects to this
request in that she…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…Any Documents containing any Communications You have had with any law enforcement
agency.
RESPONSE:
21
Case 1:15-cv-07433-LAP Document 1332-8 Filed 01/08/24 Page 23 of 27
In addition to the Preliminary Statement and…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…380 F.3d 110 (2d Cir. 2004) (per curiam)
(witnesses and third parties "possess strong privacy interests,
because being identified as part of a law enforcement
investigation could subject them to 'embarrassme nts and
harassment'" ), "with the deviant and the…
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