giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…594 F.2d
at 295-97.
H. Protecting criminal investigations and the privacy and safety of witnesses and
suspects in criminal investigations. The courts have an obligation to safeguard the
integrity of criminal investigations and the privacy and safety of…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
…clearly asked solely for the purpose of
embarrassing, intimidating and harassing a non-party already fearful for her safety and life based
upon the abuse she suffered at the hands of Defendant and Epstein, abuse as to which she
testified…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…explained in the Advisory Committee Notes regarding the 1994 amendments to Rule
412, ‘[t]he rule aims to safeguard the alleged victim against the invasion of privacy, potential
embarrassment and sexual stereotyping that is associated with public disclosure of intimate…
giuffre-maxwell
gov.uscourts.nysd.447706.1105.0
8 pg
…The Protective Order was meant to protect the interests of
numerous individuals beyond just the parties, and the Court maintains a duty to safeguard those
interests. See infra Part II.
Case 1:15-cv-07433-LAP Document 1105 Filed…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…whether she will reveal here address to Defendant’s counsel
confidentially and we will update you with her response.
a. Due to safety concerns with respect to Ms. Giuffre and her minor children,
she is not at liberty to reveal…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.22
40 pg
…Q. -- through here as GM --
19 A. Yes.
20 Q. -- just by the initials, are we able to
21 safely know that that is Ghislaine Maxwell?
22 A. Yes.
23 MR. PAGLIUCA: Object to form and
24 foundation.
25 MR…
giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…*1 n.1.
Second, the McCord court conceded that safeguarding a sexual assault victim’s identity is
“a compelling reason” not just to redact names, but to “limit the general public’s access to
[complete] documents filed in a case…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.0
35 pg
…Judge Nathan can sufficiently safeguard Maxwell’s right to
13
Case 1:15-cv-07433-LAP Document 1156 Filed 11/19/20 Page 18 of 19
a fair trial through the voir dire process and by instructing jurors against…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.3
223 pg
…notice anything to my
20 law office for Virginia. She's had some safety
21 issues with respect to her location so we're not
22 going to be putting that on the record.
23 MS. BORJA: That's fine…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…angered by our coverage.”6
As the Second Circuit highlighted, “the press plays a vital role in ensuring the public right of access
and in enhancing the quality and safeguards the integrity of the factfinding process. When
4
See https:/…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…whether she will reveal here address to Defendant’s counsel
confidentially and we will update you with her response.
a. Due to safety concerns with respect to Ms. Giuffre and her minor children,
she is not at liberty to reveal…
giuffre-maxwell
gov.uscourts.nysd.447706.1067.0
10 pg
…App’x 723, 725 (2d Cir. 2017) (noting generally that protection of ongoing
investigations and safety of witnesses may be countervailing interests).
However, Ms. Maxwell’s generalized assertion that there are ongoing criminal
investigations is wholly insufficient to warrant sealing…
giuffre-maxwell
gov.uscourts.nysd.447706.503.0
21 pg
…particular v igilance . . in
safeguarding the free press against undue inter ference ," and
"prevent(ing] undue diversion of journalistic effort and
disruption of press functions." 71 N.Y.2d at 528-29 (disc u ssing
New York Constitution, article I, …
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…whether she will reveal here address to Defendant’s counsel
confidentially and we will update you with her response.
a. Due to safety concerns with respect to Ms. Giuffre and her minor children,
she is not at liberty to reveal…
giuffre-maxwell
gov.uscourts.nysd.447706.68.0
17 pg
…witnesses.
Regarding Ms. Giuffre’s own address, she is a child victim of sex trafficking. As a result of
personal safety concerns, Ms. Giuffre disclosed her attorney’s address and agreed to accept service
at that address. During the meet…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…Page 9 of 18
rights: “The Court will ensure strict compliance with [the Court’s local rules and the rules of
professional responsibility] and will ensure that the Defendant’s right to a fair trial will be
safeguarded.” DE 28…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.40
19 pg
…Royal Palm Beach (Florida) Police Department, the
County Court in and for Palm Beach County (Florida), the Greenacres
(Florida) Department of Public Safety, and the Fremont County (Colorado)
Sheriff’s Office.
9. Employment records obtained from ET Employment Training and…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…A at 199:3-23. It is axiomatic that any conversations between Ms. Ransome and Mr.
Dershowitz in the presence of Jeffrey Epstein, a third party, are not protected by privilege.
Safeco Ins. Co. of Am. v. M.E.S.…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…to encompass
woman's decision whether or not to terminate her pregnancy, but
that this right is not absolute in that the state may properly
assert important interests in safeguarding health, in
maintaining medical standards and in protecting potential life).…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…
Unfortunately, I cannot send you the footage without her consent due to massive consequences to
her safety but I can confirm that I do have footage in my possession. I have backed up the footage
on several USB sticks and…
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