giuffre-maxwell
gov.uscourts.nysd.447706.719.0
1 pg
…201 7, the Court
addressed and resolved the ore tenus motion requesting the redaction of the non-party's witness
name, that did not address the substance of the Non-Party's Motion for Protective Order which
seeks relief from…
giuffre-maxwell
gov.uscourts.nysd.447706.1119.0_3
4 pg
…exhibits. Upon the issuance of its
mandate, the Second Circuit specifically made these materials available on its own docket,
subject to what it held were appropriate redactions for personally identifying information, names
of alleged minor victims of sexual abuse, and…
giuffre-maxwell
gov.uscourts.nysd.447706.1128.0_4
1 pg
…1079 at 3-4). The Court already reviewed
and approved Plaintiff’s proposed redactions for these documents, and Plaintiff has verified that
redactions are in place for each of the categories of information identified in the Court’s July 30…
giuffre-maxwell
gov.uscourts.nysd.447706.1167.2
27 pg
…but the redactions of the
names of Non-Parties whose time
to object has expired should be
removed…
giuffre-maxwell
gov.uscourts.nysd.447706.1157.0_1
5 pg
…Non-Party Notice to all remaining Non-Parties was to
expedite the review process by minimizing the number of
redactions applied at each round and allowing the Court to have
more clarity on which Non-Parties were actually objecting to…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…crucially that the Second Circuit, by its redactions, implicitly held
that the deposition contained “responses concerning intimate matters where the questions were
likely only permitted – and the responses only compelled – because of a strong expectation of
continued confidentiality.” See Resp…
giuffre-maxwell
gov.uscourts.nysd.447706.1318.0
3 pg
…her
current country, the Parties and the Miami Herald consent to
redacting Doe 107's name and any personally identifying
information in the docket entries that the Court previously
ordered unsealed. Giuffre's and the Miami Herald's consent to…
giuffre-maxwell
gov.uscourts.nysd.447706.1225.0
2 pg
…as Ms. Maxwell proposes, then a
single document such as initial disclosures or a witness list will continue to resurface in every
round, only to have redactions removed from a few names each time, thereby multiplying the
review. Instead, if…
giuffre-maxwell
gov.uscourts.nysd.447706.1038.0
2 pg
…orders.
Second, Defendant proposes that paragraph 3(e) be deleted in its entirety. Plaintiff
disagrees. This paragraph allows the Court to determine what redactions are appropriate, in
consultation with the parties, before filing Non-Parties’ objections on the docket. To…
giuffre-maxwell
gov.uscourts.nysd.447706.1248.0
6 pg
…other. As discussed in more detail below, the former group can maintain privacy by narrowly
redacting information that would identify those who have not previously been publicly identified
1
As with prior filings, counsel for Intervenors have seen only Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1195.0_2
2 pg
…Intervenors do not have access to the unredacted letter and can only understand the
contents based on the context surrounding the redactions.
Anchorage | Atlanta | Austin | Boston | Charlotte | Chicago | Dallas | Denver | Fort Lauderdale…
giuffre-maxwell
gov.uscourts.nysd.447706.1083.0
3 pg
…personal identifying information as to any
person mentioned in the documents,” 2) “the names of nonparties other than Does 1 and 2,”
and 3) “other portions related to such nonparties’ specific conduct.” The rationale for
redacting categories 2 and 3…
giuffre-maxwell
gov.uscourts.nysd.447706.1339.0
3 pg
…unsealing in full, that finding related only to
the mentions of the specific Doe, not to any and all redactions in
the document.
As counsel is aware, this case has attracted a great deal of
public attention, and there are…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…non-
parties is no longer appropriate. Plaintiff respectfully requests that the Parties be permitted to
review and publish the sealed materials subject to redactions to protect the names and personally
identifiable information of victims only, which would greatly expedite the…
giuffre-maxwell
gov.uscourts.nysd.447706.1107.0
2 pg
…may be made ad hoc.
5. Proposed Redactions: The Court will not require the Original
Parties to include with any brief in support of unsealing a
sealed set of proposed redactions for in camera review.
6. Appeals: Counsel for Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1167.0
31 pg
…Attached as Exhibit E (Filed Under Seal) is true and correct copy of DE 340-1
with Ms. Maxwell’s Proposed Redactions as described in her Reply Memorandum.
3. Attached as Exhibit F is an Amended summary chart of Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1317.0
3 pg
…her
current country, the Parties and the Miami Herald consent to
redacting Doe 107's name and any personally identifying
information in the docket entries that the Court previously
ordered unsealed. Giuffre's and the Miami H…
giuffre-maxwell
gov.uscourts.nysd.447706.1129.0_5
2 pg
…to confirm that her
counsel may release “later today” the previously unsealed deposition testimony of Ms.
Maxwell and Doe 1 (“Unsealed Materials”), while redacting Doe 1’s name from the materials
that will be filed. We oppose Plaintiff’s request…
giuffre-maxwell
gov.uscourts.nysd.447706.444.0
2 pg
…materials in this way. Moreover, these improper redactions are in derogation of the
“general right to inspect and copy public records and documents, including judicial records and
documents,” that has long been recognized by the Supreme Court. See Nixon v…
giuffre-maxwell
gov.uscourts.nysd.447706.920.0
2 pg
…denial of summary judgment was filed in redacted form on April 27,
2017, implicitly denying Cernovich Media’s Opposition to Notice of Plaintiff’s Proposed
Redactions to this Court’s Order Denying Summary Judgment (ECF No. 833).
Dated: May 31…
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