giuffre-maxwell
gov.uscourts.nysd.447706.551.0
17 pg
…because Maxwell has filed
a motion for summary judgment which could lead to the adjudication of this case. Due to all the
redactions in the record, even the reasons for the Protective Order are hidden from the public.
(ECF No…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…to these documents is thus unnecessary. Accordingly, and
to avoid any further delay,21 we order that the summary judgment
documents (with minimal redactions) be unsealed upon issuance of
our mandate.22
18 Id. at 123.
19 Id. at 124.
…
giuffre-maxwell
gov.uscourts.nysd.447706.978.0
27 pg
…to these documents is thus unnecessary. Accordingly, and
to avoid any further delay,21 we order that the summary judgment
documents (with minimal redactions) be unsealed upon issuance of
our mandate.22
18 Id. at 123.
19 Id. at 124.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1143.0_1
2 pg
…the 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…
giuffre-maxwell
gov.uscourts.nysd.447706.993.0
28 pg
…applied. Rather, the Court will
need to review the redactions to the motion itself to ensure that its redactions are limited to
Maxwell’s financial information, as opposed to anything else she designated as Confidential under
the Protective Order. See…
giuffre-maxwell
gov.uscourts.nysd.447706.1052.0
4 pg
…of the 98 Non-Parties
totals 987 pleadings. Each of those pleadings would have to be un-redacted to reveal that Non-
leaving all other redactions for each other Non-Party mentioned in that
pleading intact. By way of example…
giuffre-maxwell
gov.uscourts.nysd.447706.1182.0_1
3 pg
…and testimony that have been disclosed to
Mr. Dershowitz in discovery, or the extent to which those materials identify non-parties. Indeed,
it is possible that through redactions, limited productions or otherwise, these materials do not
identify non-parties. See…
giuffre-maxwell
gov.uscourts.nysd.447706.898.0
4 pg
…Court and the public—could
legitimately be deemed confidential.
Similarly, the Court characterized the redactions to its summary judgment decision as
“omit[ting] only the confidential fact contentions of the parties resulting from the
discovery.” ECF No. 892 at 5…
giuffre-maxwell
gov.uscourts.nysd.447706.1215.0
13 pg
…in the same
manner as released in the Second Circuit. Plaintiff repeats her earlier stated position: “Unseal in
full.; Note: These pages of this deposition transcript were released by the Second Circuit without
redactions.” See, e.g., DE 1167-2…
giuffre-maxwell
gov.uscourts.nysd.447706.1308.1
465 pg
…on the top right-hand
25 corner.
Case 1:15-cv-07433-LAP Document 1308-1 Filed 08/25/23 Page 26 of 465
Page 25
1 G Maxwell - Confidential
2 You will see some redactions in
3 this report…
giuffre-maxwell
gov.uscourts.nysd.447706.1118.0
21 pg
…As to the summary judgment materials, the Second Circuit went so far as to determine itself,
over dissent, the specific summary judgment materials that were unsealed and what redactions
would be made. Id. at 48 (“we order that the summary…
giuffre-maxwell
gov.uscourts.nysd.447706.1155.0_2
13 pg
…315, 320, and 335, and their related
submissions—as well as all docket entries that received no objection—should be unsealed with
minimal redactions.2 Additionally, the objections raised in Ms. Maxwell’s November 18, 2020
letter regarding the J…
giuffre-maxwell
gov.uscourts.nysd.447706.977.0
27 pg
…to these documents is thus unnecessary. Accordingly, and
to avoid any further delay,21 we order that the summary judgment
documents (with minimal redactions) be unsealed upon issuance of
our mandate.22
18 Id. at 123.
19 Id. at 124.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.0
3 pg
…are. Moreover, Plaintiff disagrees with Maxwell to the extent this
proposed language suggests that the Parties’ briefs should only be “served” on each objecting Doe,
as opposed to being filed on ECF with appropriate redactions in place. Paragraph 3.e…
giuffre-maxwell
gov.uscourts.nysd.447706.1349.0
31 pg
…Case: 24-182, 07/23/2025, DktEntry: 95.1, Page 8 of 31
Case 1:15-cv-07433-LAP Document 1349 Filed 07/23/25 Page 8 of 31
unsealed (subject to minimal redactions). See id. at 47–48, 53…
giuffre-maxwell
gov.uscourts.nysd.447706.1253.0
12 pg
…at 7:9–12, 21–23 (“[W]hat we are looking for from you is a specific
explanation of why the document should remain sealed or the redactions should continue specific
to that document.”). And “a generalized concern of adverse…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.9
21 pg
…hard-copies.
This matter being subject to a Protective Order, the parties
are directed to meet and confer regarding redactions to this
Opinion consistent with that Order. The parties are further
directed to jointly file a proposed redacted version of…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.4_1
4 pg
…have stated that there is "likely" no good faith basis for keeping the details of the
rape of a 14 year old girl, and the reactions of Ms. Giuffre' s minor children to domestic violence,
outside of the public realm…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.7
9 pg
…15 he needed to have three orgasms a day. It was
16 biological, like eating.
17 Q. And what was your reaction to that
18 statement?
19 A. I thought it was a little crazy.
20 Q. And what did …
giuffre-maxwell
gov.uscourts.nysd.447706.149.0
9 pg
…from asking her questions about any adult, In support of her
requests, Ms. Maxwell states:
Plaintiff initiated this action purportedly in reaction to statements attributed to Ghislaine
Maxwell on January 3, and 4, 2015. The first of the two statements…