giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…any judicial
proceeding involving Ghislaine Maxwell or Virginia Giuffre, or in any proceeding relating to
Giuffre’s allegation that Jeffrey Epstein sexually abused her.
As a non-party to these proceedings, Doe lacks specific knowledge about the contents of
the…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…are unfounded. Ms. Giuffre has repeatedly confirmed that her interest
was that all of the filings in the district court docket should be unsealed so that the public may
have a complete picture of the abuse she suffered. (Dkt. 945…
giuffre-maxwell
gov.uscourts.nysd.447706.551.0
17 pg
…government
officials, media moguls and high profile business people. Cernovich Media is an organization
whose mission is to use and promote investigative journalism as a tool to expose corruption and
abuse of public power by promoting transparency, accountability, and public…
giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…The Intervenors’ requests to unseal should be denied.
A. Intervenors’ First Proposition of Law: For minor victims of sexual abuse, “redactions
should be applied sparingly to shield only information that would identify those who
have not already been publicly identified…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…Docket Entries. ............. 8
A. “Personal” Information in Maxwell’s Deposition Transcript Does Not Warrant
Continued Sealing. .............................................................................................................. 9
B. The Potential for “Media Abuse” Does Not Warrant C…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…hidden from public view, in her public lawsuit
designed to promote her well-orchestrated media campaign.
The police reports reflect as to the late 1990s and early 2000s, Plaintiff’s substantial
substance abuse, her lack of credibility, her failures of…
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.447706.1134.0_5
2 pg
…Id. at 1. But it should not
come as a surprise that those “non-parties,” including those implicated as potential abusers within
Jeffrey Epstein’s sex-trafficking conspiracy, would seek to obscure as much information
concerning their conduct as possible…
giuffre-maxwell
gov.uscourts.nysd.447706.1135.0_6
1 pg
…identity or any conduct attributed to them (including
as either an alleged victim of Mr. Epstein’s abuse or as a perpetrator of any such abuse) is
disclosed publicly.
Respectfully submitted,
Laura A. Menninger
CC: Counsel of Record via ECF
giuffre-maxwell
gov.uscourts.nysd.447706.1248.0
6 pg
…values.” See Delta Air
Lines, 2020 WL 2614704, at *4.
Intervenors address the Does’ objections based on the categories under which the Does
fall: victims of sexual abuse, on the one hand, and those accused of wrongdoing or who were…
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.447706.1155.0_2
13 pg
…weight.” Id. The Second
Circuit affirmed these findings, holding this Court “did not abuse its discretion in rejecting
Maxwell’s meritless arguments that her interests superseded the presumption of access.” Giuffre,
827 F. App’x 144.
Yet, with this second…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.6_1
14 pg
…hidden from public view, in her public lawsuit
designed to promote her well-orchestrated media campaign.
The police reports reflect as to the late 1990s and early 2000s, Plaintiff’s substantial
substance abuse, her lack of credibility, her failures of…
giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…Preska
November 16, 2019
Page 3
numbers,” and “the names of alleged minor victims of sexual abuse from deposition
testimony and police reports, as well as deposition responses concerning intimate
matters where the questions were likely only permitted—and the…
giuffre-maxwell
gov.uscourts.nysd.447706.1196.0
32 pg
… This
4 testimony is, in any case, far afield from the sex trafficking
5 and sexual abuse allegations that were central to the dispute
6 in Giuffre v. Maxwell. Although the prurient interest of some
7 may be left unsatiated…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…the redactions were
agreed upon by the parties, they were solely at Defendant’s request. This is a case concerning sex
abuse of minors, brought by a minor victim of sex abuse. If any civil case cries out for protective…
giuffre-maxwell
gov.uscourts.nysd.447706.1242.0
9 pg
…such.
3
Case 1:15-cv-07433-LAP Document 1242 Filed 02/16/22 Page 5 of 9
Case 1:15-cv-07433-LAP Document 1242 Filed 02/16/22 Page 6 of 9
alleged victims of sexual abuse…
giuffre-maxwell
gov.uscourts.nysd.447706.1284.0
17 pg
…C.
(212) 805-0300
MBIMGUIC
Case 1:15-cv-07433-LAP Document 1284 Filed 12/02/22 Page 6 of 17 6
1 identity should be sealed because she was a victim of serious
2 abuse by Jeffrey Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1283.0
17 pg
…C.
(212) 805-0300
MBIMGUIC
Case 1:15-cv-07433-LAP Document 1283 Filed 12/02/22 Page 6 of 17 6
1 identity should be sealed because she was a victim of serious
2 abuse by Jeffrey Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.0
35 pg
…correctly
held that the deposition materials are judicial documents to which the presumption of public access
attaches, and did not abuse its discretion in rejecting Maxwell’s meritless arguments that her
interests superseded the presumption of access.” Id. (emphasis added)…
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