giuffre-maxwell
gov.uscourts.nysd.447706.1231.0
3 pg
…the public docket in the unsealing protocol dated August 27, 2020:
The Court’s staff will receive Non-Party submissions, make appropriate redactions,
e.g., the Non-Party’s identifying information (with the assistance of the Original
Parties, as appropriate)…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.3_2
12 pg
…ghislaine-maxwell-testimony-jeffrey-epstein-released-2020-10
19 https://slate.com/news-and-politics/2020/10/ghislaine-maxwell-deposition-redactions-epstein-how-to-crack.html
20 https://www.independent.co.uk/news/world/ghislaine-maxwell-deposition-jeffrey-epstein-accuser…
giuffre-maxwell
gov.uscourts.nysd.447706.851.0
158 pg
…7 allegations concerning sexual abuse and the activities of the
8 defendant. I think that's my sense of my own opinion.
9 Yesterday, we were discussing the redactions of the
10 intervention motion. I got the sense, perhaps wrongly…
giuffre-maxwell
gov.uscourts.nysd.447706.994.0
14 pg
…and common law rights of access. Therefore, the
remaining documents should be immediately unsealed with only very limited exceptions and
minor redactions for social security numbers, the names of alleged minor victims and their
relations, and other personal identifying information…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…corrected, six-page brief.
2
Case 1:15-cv-07433-LAP Document 1068 Filed 06/24/20 Page 7 of 24
explanation of why the document should remain sealed or the redactions should continue specific
to that document. I…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…reports at
issue by interposing a simple request to the law enforcement agency and paying any applicable
4
Case 1:15-cv-07433-LAP Document 1328-20 Filed 01/05/24 Page 7 of 14
copying and redaction fees…
giuffre-maxwell
gov.uscourts.nysd.447706.1196.0
32 pg
… By his letter at docket entry
11 1138, he has requested that redactions of his name in these
12 materials be unsealed in all cases.
13 Finally, excerpts of any deposition testimony for
14 nonparty Does in the Court of…
giuffre-maxwell
gov.uscourts.nysd.447706.1353.0
6 pg
…well,” Act § 2(a)(1)–(2), the Act requires the Government to publish the Materials subject to ap-
propriate redactions regarding victim-identifying information.
However, the Materials are subject to both (1) a protective order in this case (Dkt. 62)…
giuffre-maxwell
gov.uscourts.nysd.447706.1034.0
16 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.447706.1199.16_1
12 pg
…has her name redacted. Of course, such a redaction does Ms. Giuffre little good when
Defendant and her cohorts distribute it to the press - the identity of the victim in the police report
will presumably be supplied by Defendant. Indeed…
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.447706.1156.0
35 pg
…the
Court should instead unseal the documents in their entirety, subject only to (1) the “minimal
redactions” the Second Circuit applied to the summary judgement record, 1 and (2) redactions of
the names of Non-Parties that have submitted Non…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…has her name redacted. Of course, such a redaction does Ms. Giuffre little good when
Defendant and her cohorts distribute it to the press - the identity of the victim in the police report
will presumably be supplied by Defendant. Indeed…
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…
giuffre-maxwell
gov.uscourts.nysd.447706.995.0
11 pg
…and accordingly the entire record should be unsealed, subject to redactions
similar to what the Second Circuit applied. The various steps in John Doe’s protocol requiring the
parties to make joint submissions to the Court are a transparent attempt…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…Pottinger here for a nonparty witness. If I slip and use her
9 name, I believe your Honor's redaction order of two weeks ago
10 probably covers this. If I'm wrong about that, I'll be happy
11…
giuffre-maxwell
gov.uscourts.nysd.447706.1025.0
17 pg
…judicial document,
(a) the weight of presumption of public access that should be afforded it, (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.447706.949.0
31 pg
…14 My clients aren't here for prurient interest, and of
15 course we would agree to things like redacting names and
16 substituting initials and things like that. They don't
17 identify the names of victims of sexual…
giuffre-maxwell
gov.uscourts.nysd.447706.849.0
94 pg
…17 MS. MENNINGER: So, you know, alluding to that point,
18 your Honor, there are so many redactions, it's unclear who
19 wrote the report, but more importantly, the content of the
20 report is so heavily redacted, we…