giuffre-maxwell
gov.uscourts.nysd.447706.41.5
18 pg
…ORDER
Upon a showing of good cause in support of the entry of a protective order to protect
the discovery and dissemination of confidential information, including sensitive personal
information relating to a victim of sexual abuse, copyright or trade secrets…
giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…as Ms. Maxwell did, defending a defamation lawsuit
in name only. Plaintiff and her lawyers convert their defamation claim to one of sexual abuse
against the defamation defendant. So to prove plaintiff is a liar, Mr. Dershowitz is interested in…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…used his vast wealth and property holdings and a deliberately opaque web of
corporations and companies to transport young women and girls to his privately-owned islands
where they were held captive and subject to severe and extensive sexual abuse…
giuffre-maxwell
gov.uscourts.nysd.447706.1302.0
3 pg
…of “any and all documents” filed in Giuffre v. Maxwell that “identify the men who abused
the girls trafficked by Jeffrey Epstein and Defendant Maxwell.” Appellant’s App’x at 260. The
District Court denied TGP’s motion to intervene…
giuffre-maxwell
gov.uscourts.nysd.447706.1126.0
3 pg
…Maxwell’s April 2016 deposition transcript. She argues
that the District Court abused its discretion in ordering the unsealing of the deposition materials.
Specifically, she argues that there is a lower presumption of access to the deposition materials at
issue…
giuffre-maxwell
gov.uscourts.nysd.447706.1119.0_3
4 pg
…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 deposition responses disclosing intimate matters.
Id…
giuffre-maxwell
gov.uscourts.nysd.447706.1167.2
27 pg
…Non-Parties whose time
to object has expired should be
removed.
1
Key:
CI-1 - Reasonable reliance the Protective Order by a party or non-party.
CI-2 - Prevention of th…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.17
13 pg
…of Confidential Materials. This
Court should issue an Order to Show Cause.
FACTUAL BACKGROUND
Ms. Giuffre sought to convert her defamation action into a lawsuit for child “sexual
abuse” and “sexual trafficking” of children. Toward that end, she made numerous…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.42
5 pg
…that I had, just everything that was kind of
CONFIDENTIAL
GIUFFRE005156
CONFIDENTIAL
Case 1:15-cv-07433-LAP Document 1219-42 Filed 07/15/21 Page 4 of 5
…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.4_1
4 pg
…Other materials you produced include police records concerning my client while she
was a minor child, and police records showing my client as a victim of domestic abuse, which
include descriptions of her minor children.
As far as my good…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…information.
2. Ransome objects to Defendant’s clear abuse of the subpoena power of this Court
as she issued subpoena requests that are intended to obtain discovery for the development of
another action relating to this non-party, and are…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…information.
2. Ransome objects to Defendant’s clear abuse of the subpoena power of this Court
as she issued subpoena requests that are intended to obtain discovery for the development of
another action relating to this non-party, and are…
giuffre-maxwell
gov.uscourts.nysd.447706.995.0
11 pg
…background of this case, to serve as a de facto Special Master over a process governing which
documents the public is allowed to access concerning this matter involving the serious issue of
abuse of minors.
1. Who Is John Doe…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…and lawyer vitriol into
1
The Countervailing Interests include:
1. Reasonable reliance on the Protective Order by a party or non-party (“CI-1”).
2. Prevention of the abuse of court records and files (“CI-2”).1
3. Annoyance, embarrassment…
giuffre-maxwell
gov.uscourts.nysd.447706.96.0
15 pg
… Documents Evidencing Communications and Interactions With
Co-Conspirators.............................................................................................................3
B. Documents Concerning Sexual Abuse And Trafficking Of Females............................4
III. ARGUMENT – FORE…
giuffre-maxwell
gov.uscourts.nysd.447706.928.0
11 pg
…Documents
The Court took care to have the parties enter into the Protective Order in this case given
the sensitive nature of the sexual abuse allegations at issue.
There is a “strong presumption against the modification of a protective order…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.4
23 pg
…ORDER
Upon a showing of good cause in support of the entry of a protective order to protect
the discovery and dissemination of confidential information, including sensitive personal
information relating to a victim of sexual abuse, copyright or trade secrets…
giuffre-maxwell
gov.uscourts.nysd.447706.149.0
9 pg
…wit, that Ms. Maxwell “assisted” and participated in
sexual abuse of the Plaintiff between 1999 and 2002.
Plaintiff does not claim that any sexual abuse occurred after 2002 or that she had any
contact with Ms. Maxwell after 2002. Indeed…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.14
3 pg
…com/ news/worJd/sex-slave-prince-andrew-accused-2-men-rape-1998-article-1.2125569
Mom told a detective "about her daughte r's past dmg abuse and also how many kids in Royal Palm Beach are
involved in drngs…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…information.
2. Ransome objects to Defendant’s clear abuse of the subpoena power of this Court
as she issued subpoena requests that are intended to obtain discovery for the development of
another action relating to this non-party, and are…
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