giuffre-maxwell
gov.uscourts.nysd.447706.1150.3_2
12 pg
…maxwell-deposition-gives-insight-into-epstein-relationship-94465093962
27 https://pagesix.com/2020/10/26/alan-dershowitz-seeks-to-unredact-name-in-ghislaine-maxwell-deposition/
28 https://www.reuters.com/article/people-ghislaine-maxwell/ghislaine-maxwell-repeatedly-denies-witnessing-underage…
giuffre-maxwell
gov.uscourts.nysd.447706.1155.0_2
13 pg
…counsel for Intervenors have seen only the redacted versions of these
documents that are available on the public docket and submit this response based on the known
portions of the documents as well as the parties’ public representations as to…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.6_1
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…
giuffre-maxwell
gov.uscourts.nysd.447706.983.0
24 pg
…Good morning, ladies and gentlemen. Won't
3 you be seated. Giuffre against Maxwell.
4 Counsel, please tell me how your client pronounces her
5 name.
6 MS. McCAWLEY: It's Giuffre, Virginia Giuffre.
7 THE COURT: Yes, ma'am. …
giuffre-maxwell
gov.uscourts.nysd.447706.1253.0
12 pg
…concerning the first set of Non-Party Objectors, the Court ordered that certain documents would
remain under seal where (i) a Non-Party Objector’s name was only mentioned in “a case of
mistaken identity”; (ii) Non-Party Does were…
giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…s objection claims that unsealing would be detrimental to
their wellbeing. Plaintiff does not object to keeping Doe 28’s name sealed in excerpts that discuss
Doe 28 being sexually abused. 4 Such excerpts should redact Doe 28’s name…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…Maxwell contends in her objection that
the Court cannot unseal any of the first five motions or their related docket entries until each
Non-Party is separately noticed in the order that their name appears on the Non-Party list…
giuffre-maxwell
gov.uscourts.nysd.447706.1196.0
32 pg
…For the sake of efficiency, my chambers will share
12 with the parties a copy of the transcript that highlights the
13 portions of Ms. Maxwell's deposition that should remain
14 redacted. This will avoid, I know you're…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…s deposition. Plaintiff
fails to mention that DE 172’s redactions also include purported “summaries” of Doe 162’s
deposition and the purported anticipated deposition testimony of Doe 84 (whose name and
testimony the Second Circuit redacted in Brown). Both…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.4
106 pg
…Maxwell, the redacted
4 MR. PAGLIUCA: I'm going to object 4 information is redacted because it reveals
5 to you interrupting the witness who was 5 the name of a minor, someone who is under the
6 answering your…
giuffre-maxwell
gov.uscourts.nysd.447706.1220.0
17 pg
…conference.
15 Additionally, as before, Alan Dershowitz's name and
16 information identifying him may be unsealed. As you know by
17 his letter at docket entry 1138, he has requested that
18 redactions of his name in these materials…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.22
22 pg
…to you, please notify and confirm that it has been
deleted from your system and no copies made.
This Firm is authorised and regulated by the Solicitors Regulation Authority under the name of Devonshires
Solicitors and registration number 0049857. This…
giuffre-maxwell
gov.uscourts.nysd.447706.1284.0
17 pg
…criminal
19 trial.
20 About six documents concerning Doe number 28,
21 Ms. Giuffre supports the unsealing except for the redaction of
22 Doe 28's name. Plaintiff takes no position as to approximately
23 26 of the documents.
24 …
giuffre-maxwell
gov.uscourts.nysd.447706.1283.0
17 pg
…criminal
19 trial.
20 About six documents concerning Doe number 28,
21 Ms. Giuffre supports the unsealing except for the redaction of
22 Doe 28's name. Plaintiff takes no position as to approximately
23 26 of the documents.
24 …
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…under
the express promise of confidentiality. The Second Circuit sua sponte redacted Doe #84’s name
from summary judgment pleadings finding that Doe’s privacy interests outweighed the “strong
presumption” of access inherent to those pleadings. Doe #84 has not…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.0
35 pg
…Maxwell Br. at 2-4. Maxwell
notes that in the Brown appeal, the Second Circuit redacted portions of the July 2016 deposition
that were a part of the summary judgment record. Maxwell Br. at 3. But as that document shows…
giuffre-maxwell
gov.uscourts.nysd.447706.1213.0
18 pg
…argues that Docket Entry 388—Plaintiff’s Response In Opposition to
Defendant’s Motion for Protective Order Regarding Financial Information—should remain
redacted because the only current redactions are of the names of Non-Parties and other personally
identifying information…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…case. That's their listing. All it
17 is is the names of people.
18 I have absolutely no idea or ability to understand why
19 someone's name could be considered to be confidential. It is
20 their name…
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…that she had undergone extensive therapy to overcome the trauma and did not
want to be involved in the proceedings at all. The Second Circuit sua sponte redacted this Doe
#84’s name from otherwise unsealed summary judgment pleadings. See…
giuffre-maxwell
gov.uscourts.nysd.447706.1067.0
10 pg
…the public.
E. Improper Submission of Documents
Ms. Maxwell contends that documents submitted for a “non-merits purpose” should remain
sealed or redacted if there is any interest in sealing or redaction. The case she cites, SEC v.
TheStreet.com…