giuffre-maxwell
gov.uscourts.nysd.447706.1034.0
16 pg
…2019).
4. Notice of Appellate Rights: The Protocol will include the
provision notifying non-parties of their appellate rights
with respect to any decision to unseal a document mentioning
their name. That provision will provide that “[a]n order
from…
giuffre-maxwell
gov.uscourts.nysd.447706.1021.0
18 pg
…the first five or something like that.
11 MS. WALZ: To the extent there is a third-party name
12 or something like that that counsel feels must be redacted, can
13 it be just redacted?
14 THE COURT: Of…
giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…See id. at *3 (“The respondents d[id] not contend that the [state-court documents] were
filed under seal or redacted in the state court to protect the identity of the victim of sexual
abuse.” (internal quotation marks omitted)), but…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.5
465 pg
…report, Ms. Maxwell, the redacted
4 information is redacted because it reveals
5 the name of a minor, someone who is under the
6 age of 18.
7 On page 28, in the third paragraph,
8 about halfway down, it…
giuffre-maxwell
gov.uscourts.nysd.447706.1167.2
27 pg
…in criminal CI-4 expired.
trial and depo testimony potential CI-5 Note: The Original Parties sent
evidence; Second Circuit redacted CI-6 the Non-Party deponent (Doe 83)
this Doe’s name and information; CI-7 notice of unsealing…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.1
465 pg
…report, Ms. Maxwell, the redacted
4 information is redacted because it reveals
5 the name of a minor, someone who is under the
6 age of 18.
7 On page 28, in the third paragraph,
8 about halfway down, it…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.1
4 pg
…Court (Dkt. 1007-1).
Case 1:15-cv-07433-LAP Document 1026-1 Filed 01/30/20 Page 2 of 4
The Non-Parties List will:
Identify each Non-Party by his or her name, which correlates to…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.13_5
465 pg
…report, Ms. Maxwell, the redacted
4 information is redacted because it reveals
5 the name of a minor, someone who is under the
6 age of 18.
7 On page 28, in the third paragraph,
8 about halfway down, it…
giuffre-maxwell
gov.uscourts.nysd.447706.1025.0
17 pg
…contemplate that for each non-party submission the Court’s staff would substitute
in the redacted version the pseudonymous identifier for the non-party’s name, redact
as appropriate the submission, and file the redacted version in the ECF system…
giuffre-maxwell
gov.uscourts.nysd.447706.949.0
31 pg
…13 MR. BOHRER: Thank you, your Honor.
14 Your Honor, my name is Sandy Bohrer with the law firm
15 of Holland & Knight. We represent the Miami Herald. We're
16 seeking to intervene. We're the third party that…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.31
13 pg
…On page 4, Defendant claims that actual police reports are “highly relevant,” stating: “the
publicly available, redacted police reports are part of the record and constitute highly relevant
evidence in this action.” But, on the very next page, when discussing…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.1
7 pg
…are alleged to have been victimized.
3
Case 1:15-cv-07433-LAP Document 1232-1 Filed 10/29/21 Page 3 of 7
The Non-Parties List will:
Identify each Non-Party by his or her name…
giuffre-maxwell
gov.uscourts.nysd.447706.201.0
5 pg
…c]ertain witnesses' . . . names
[were] redacted in accordance with the protective order”).
The Court’s inherent power to protect witnesses is crucial when applied to protect
witnesses who are victims of, or witnesses to, sexual abuse and sexual crimes. Indeed…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.8
29 pg
…victim against any person who “prior to open judicial 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…
giuffre-maxwell
gov.uscourts.nysd.447706.1044.0
13 pg
…persons who are alleged to have been victimized.
The Non-Parties List will:
1
Case 1:15-cv-07433-LAP Document 1044 Filed 03/31/20 Page 2 of 13
• Identify each Non-Party by his or her name…
giuffre-maxwell
gov.uscourts.nysd.447706.363.0
18 pg
…the Court grants my application, I would also request that the Court
unseal the Requested Documents along with all of the references to them in my motion papers
that are being redacted from the public docket.
4.
2
5. …
giuffre-maxwell
gov.uscourts.nysd.447706.1143.0_1
2 pg
…suggested edit to the Protocol, providing notice to all remaining Non-Parties speeds up the
unsealing process by minimizing the number of Non-Party names that need to be redacted from
future materials that are unsealed, and will provide greater…
giuffre-maxwell
gov.uscourts.nysd.447706.1308.1
465 pg
…report, Ms. Maxwell, the redacted
4 information is redacted because it reveals
5 the name of a minor, someone who is under the
6 age of 18.
7 On page 28, in the third paragraph,
8 about halfway down, it…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.9
18 pg
…the event the Court grants my application, I would also request that the Court
unseal the Requested Documents along with all of the references to them in my motion papers
that are being redacted from the public docket.
4. As…
giuffre-maxwell
gov.uscourts.nysd.447706.1108.0
5 pg
…persons who are alleged to have been victimized.
1
Case 1:15-cv-07433-LAP Document 1108 Filed 08/27/20 Page 2 of 5
The Non-Parties List will:
• Identify each Non-Party by his or her name…
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