giuffre-maxwell
gov.uscourts.nysd.447706.1204.0
3 pg
…2021
Honorable Loretta A. Preska
United States District Court
Southern District of New York
500 Pearl Street
New York, NY 10007
Re: Limited Motion to Reconsider Proposed Redactions of Ms. Maxwell’s July
2016 Deposition Transcript
Giuffre v. Ghislaine Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.977.2
1 pg
…of the Court’s
unsealing order: it unseals nearly 2000 pages of material. The task of identifying
and making specific redactions in such a substantial volume is perilous; the
consequences of even a seemingly minor error may be grave and…
giuffre-maxwell
gov.uscourts.nysd.447706.968.1
1 pg
…of the Court’s
unsealing order: it unseals nearly 2000 pages of material. The task of identifying
and making specific redactions in such a substantial volume is perilous; the
consequences of even a seemingly minor error may be grave and…
giuffre-maxwell
gov.uscourts.nysd.447706.1191.0_1
3 pg
…2021
Honorable Loretta A. Preska
United States District Court
Southern District of New York
500 Pearl Street
New York, NY 10007
Re: Limited Motion to Reconsider Proposed Redactions of Ms. Maxwell’s July
2016 Deposition Transcript
Giuffre v. Ghislaine Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…a) the weight of presumption of public access that should be afforded to the
document, (b) the identification and weight of any countervailing interests supporting continued
sealing/redaction, and (c) whether the countervailing interests rebut the presumption of public
access…
giuffre-maxwell
gov.uscourts.nysd.447706.1080.0
2 pg
…nonparty names will await notice to those parties and an opportunity for them to be
heard.” Id. 5:20-6:1.
Plaintiff’s counsel sent defense counsel the documents with proposed redactions on a
rolling basis, beginning on July 25…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.26
5 pg
… That's a black redaction of the
19 name of the minor and there is -- I will
20 represent for the record that's what it is.
21 You can contest that but I'm not asking about
22 the…
giuffre-maxwell
gov.uscourts.nysd.447706.1242.0
9 pg
…there is an error and that Plaintiff does not dispute that assertion. Plaintiff merely
contends that any redactions be narrowly tailored to address the countervailing interests Doe 54
raised.
II. Does 55 and 56 Have Not Rebutted the Presumption in…
giuffre-maxwell
gov.uscourts.nysd.447706.1294.0
11 pg
…1 On December 5, 2022, Doe 171 also filed a Notice of Intention to Request
Redaction, requesting that the November 18 Order transcript not be made
electronically available until the Court ruled on Doe 171’s December 5
Motion. (Dkt…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.1
4 pg
…a) the weight of presumption of public access that should be afforded to the
document, (b) the identification and weight of any countervailing interests supporting continued
sealing/redaction, and (c) whether the countervailing interests rebut the presumption of public
access…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.1
16 pg
…but the redactions of the names of Non-Parties whose
time to object has expired should be removed.
Unseal and redact only names and identifying information of
Non-Parties who have objected to unsealing or whose time to
…
giuffre-maxwell
gov.uscourts.nysd.447706.710.0
1 pg
…s Reply/Combined
Opposition; therefore, the redaction of non-party’s name on page 1 and signature block
on page 23 do not affect the original un-redacted reply or supporting declaration
submitted to the Court. Accordingly, re-filed DE…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.0
16 pg
…court
filing.” Ms. Maxwell remains concerned that Non-Parties will be reluctant to participate in
this process if their objection will itself become publicized and also believes that despite best
redaction efforts and pseudonym efforts, any objections may reveal the…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.1
7 pg
…a) the weight of presumption of public access that should be afforded to the
document, (b) the identification and weight of any countervailing interests supporting continued
sealing/redaction, and (c) whether the countervailing interests rebut the presumption of public
access…
giuffre-maxwell
gov.uscourts.nysd.447706.1010.0
3 pg
…The task can only be
properly accomplished with a thorough line-by-line review of each of the redactions
contained within the briefing papers and briefing-related papers.
It likewise is a substantial undertaking to identify even in summary fashion…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…weight of
presumption of public access that should be afforded to an item, (b) the identification and weight
of any countervailing interests supporting continued sealing/redaction of the item, and (c) whether
the countervailing interests rebut the presumption of public…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.2
4 pg
…a) the weight of presumption of public access
that should be afforded itto the document, (b) the identification and weight of any countervailing
interests supporting continued sealing/redaction, and (c) whether the countervailing interests
rebut the presumption of public access…
giuffre-maxwell
gov.uscourts.nysd.447706.1226.0
4 pg
…LAP Document 1226 Filed 08/04/21 Page 2 of 4
August 4, 2021
Page 2 of 4
The second issue arises from the parties’ failure to properly make redactions …
giuffre-maxwell
gov.uscourts.nysd.447706.1044.0
13 pg
…a) the weight of presumption of public access that should be afforded to the
document, (b) the identification and weight of any countervailing interests supporting continued
sealing/redaction, and (c) whether the countervailing interests rebut the presumption of public
access…
giuffre-maxwell
gov.uscourts.nysd.447706.1108.0
5 pg
…a) the weight of presumption of public access that should be afforded to the
document, (b) the identification and weight of any countervailing interests supporting continued
sealing/redaction, and (c) whether the countervailing interests rebut the presumption of public
access…
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