giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…AUTHORITIES .......................................................................................................... ii
I. INTRODUCTION .............................................................................................................. 1
II. FACTUAL AND PROCEDURAL BACKGROUND..............................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1050.0
12 pg
…please, when you
2 speak to say your name first so that the court reporter is able
3 to do a good transcript.
4 We have looked at your various letters regarding the
5 protocol, and with respect to paragraph…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.26
5 pg
…you see the redacted
15 portions where there is black so it blacks
16 out the name.
17 A. I see black redacted portions.
18 Q. That's a black redaction of the
19 name of the minor and there…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…this Court
Ordered Defendant to sit for a second deposition because her refusal to answer questions posed
in her first Deposition (June 20, 2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,
during her second deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…this Court
Ordered Defendant to sit for a second deposition because her refusal to answer questions posed
in her first Deposition (June 20, 2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,
during her second deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1209.1
24 pg
…468 640
DATE
DOC. # DEFENDANT’S POSITION C/I[1] Status
FILED
Redact all citations to J. Sweet 4/16/16
Sealed Order consistent with partially
345 8.9.16
redacted Order a…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.13_1
3 pg
…your letter of June 8, 2016. The RFP requires defendant to “produce all
documents concerning Virginia Giuffre (a/k/a Virginia Roberts), whether or
not they reference her by name. This request includes, but is not limited to, all
communications…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…this Court
Ordered Defendant to sit for a second deposition because her refusal to answer questions posed
-
in her first Deposition (June 20, 2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,
during her second deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.1
16 pg
…where the Second Circuit redacted a
minor’s name.
Unseal in full.
393-2 Note: This document was released by the Second Circuit without
redactions.
Unseal and redact only names and identifying information of
393…
giuffre-maxwell
gov.uscourts.nysd.447706.1083.0
3 pg
…For example, in , plaintiff proposes redacting
the name of alleged victims in some places (e.g., pages ) but not in others (e.g., page ).
Both of these two alleged victims are represented by counsel and sought confidentiality for
their depositions…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.1
17 pg
…this Court
Ordered Defendant to sit for a second deposition because her refusal to answer questions posed
in her first Deposition (June 20, 2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,
during her second deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.5_1
3 pg
…your letter of June 8, 2016. The RFP requires defendant to “produce all
documents concerning Virginia Giuffre (a/k/a Virginia Roberts), whether or
not they reference her by name. This request includes, but is not limited to, all
communications…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.2
4 pg
…Motions to determine (1) whether it is a
judicial document, (2) if it is not a judicial document, whether it should remained
sealed/redacted, (3) if it is a judicial document, (a) the weight of presumption of public access
that…
giuffre-maxwell
gov.uscourts.nysd.447706.1028.0
5 pg
…2020
The Honorable Loretta A. Preska
United States District Court
Southern District of New York
500 Pearl Street
New York, NY 10007
Re: Defendant Maxwell’s Letter Brief re Materials That Should Remain Sealed or
Redacted
Giuffre v. Maxwell, No…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.22
31 pg
…AUTHORITIES .......................................................................................................... ii
I. INTRODUCTION .............................................................................................................. 1
II. FACTUAL AND PROCEDURAL BACKGROUND..............................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.0_2
65 pg
…1167-2), as attachments hereto. Material
subject to this Court’s January 26, 2021, order remains redacted. ECF No. 1193.
Sincerely,
/s/ Sigrid McCawley
Sigrid S. McCawley, Esq.
cc: Counsel of Record …
giuffre-maxwell
gov.uscourts.nysd.447706.1052.0
4 pg
…receive a redacted excerpt from each of the other pleadings that mention their
name. In the case of the 98 Non-Parties Plaintiff proposes notifying now, the collective number
of pleadings which would need to be individually redacted as to…
giuffre-maxwell
gov.uscourts.nysd.447706.435.1
8 pg
…Epstein abused.
10 My question was: As of December 30th, 2014 -- and you
11 don't have to give me the name right now -- is there any
12 specific girl that you had evidence Professor Dershowitz
13 abused?
14 A…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…who are alleged to have been victimized.
1
Case 1:15-cv-07433-LAP Document 1037-1 Filed 03/26/20 Page 2 of 14
The Non-Parties List will:
• Identify each Non-Party by his or her name…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…proceedings,” communicates “the name, address, or other specific identifying information”
concerning the victim. The statute is irrelevant here. One, the identifying information in the
police reports in this case was redacted, and therefore was not communicated to anyone. No
“name…
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