giuffre-maxwell
gov.uscourts.nysd.447706.1196.0
32 pg
…Ms. Maxwell from Haddon Morgan and
13 Foreman.
14 THE COURT: Good morning.
15 Counsel, as you know, today the Court announces its
16 rulings on the unsealing of the motions associated with docket
17 entries 231, 279, 315, 320…
giuffre-maxwell
gov.uscourts.nysd.447706.1099.0
4 pg
…and 659. Maxwell’s counsel rejected that
proposal based on the volume of documents and pages associated with those motions, and
suggested considering only five more motions in the next round of unsealing without specifying
which five motions she contended…
giuffre-maxwell
gov.uscourts.nysd.447706.1220.0
17 pg
…MCCAWLEY: Good morning, your Honor.
4 THE COURT: All right. May we begin, my friends.
5 Today, the Court announces its rulings on the
6 unsealing of the motions associated with docket entries 345,
7 356, 362, 370, 422, 468…
giuffre-maxwell
gov.uscourts.nysd.447706.1284.0
17 pg
…22 Page 2 of 17 2
1 THE COURT: As we all know, this is Giuffre against
2 Maxwell. Today the Court announces its rulings on the
3 unsealing of documents associated with nonparty Does 12, 28,
4 97, 107…
giuffre-maxwell
gov.uscourts.nysd.447706.1283.0
17 pg
…22 Page 2 of 17 2
1 THE COURT: As we all know, this is Giuffre against
2 Maxwell. Today the Court announces its rulings on the
3 unsealing of documents associated with nonparty Does 12, 28,
4 97, 107…
giuffre-maxwell
gov.uscourts.nysd.447706.1045.0
2 pg
…also propose that all excerpts applicable to a particular J. Doe be provided
at one time, irrespective of whether the Court is then considering all motions and pleadings
associated with that J. Doe. See Order and Protocol at 2(c)…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…Case
Numerous Publicly Available Police Reports With Redacted Juvenile
Information
In complete contradiction to her legal position in this Motion, Plaintiff and her counsel
have repeatedly filed in public documents associated with this case, police reports from Florida
…
giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…Orders, Intervenors again cite to non-binding, distinguishable
case law to insist that the non-party Does’ “desire not to be associated with this lawsuit” is not a
sufficient reason to warrant sealing, or even mere redacting of their identities…
giuffre-maxwell
gov.uscourts.nysd.447706.1248.0
6 pg
…As stated in Ms. Giuffre’s response, withholding
documents based on a person’s desire not to be associated with accusations of wrongdoing would
2
The same is true for Doe 28, who Ms. Giuffre quotes as describing themselves as…
giuffre-maxwell
gov.uscourts.nysd.447706.949.0
31 pg
…But there are cased that cited -- Alexander
19 Interactive is one of them -- that say there is a presumption
20 of access to those papers too because there is a judicial
21 function associated with every one of those motions…
giuffre-maxwell
gov.uscourts.nysd.447706.1083.0
3 pg
…pages et seq. the name of a Nonparty but leaving in the
allegation – widely reported in the press -- that is associated with the Nonparty (who has
through counsel requested an opportunity to be heard regarding unsealing), thereby assuring
that the…
giuffre-maxwell
gov.uscourts.nysd.447706.1226.0
4 pg
…e.g., Jim Mustian and Larry Neumeister, Epstein Ex Maxwell Denied
Getting Prince Andrew Sex Partners, ASSOCIATED PRESS (Oct. 22, 2020),
https://apnews.com/article/us-news-new-york-jeffrey-epstein-ghislaine-maxwell-manhattan-
b05b397ce139a755f8a65a667e768452. These disappointing efforts undermine the…
giuffre-maxwell
gov.uscourts.nysd.447706.1351.0
32 pg
…Giuffre charged defendant
Ghislaine Maxwell, an Epstein associate, with defaming her by publicly
calling her statements implicating Maxwell in Epstein’s trafficking “obvious
6
Case:
Case:24-182,
24-182,01/08/2026,
07/2…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…process to
refute false accusations, non-parties whose names become associated with misconduct can suffer
the “unfairness of being stigmatized from sensationalized and potentially out-of-context
insinuations of wrongdoing” utterly bereft of any opportunity to respond. United States v…
giuffre-maxwell
gov.uscourts.nysd.447706.148.0
9 pg
…ruling and order production of the information
forthwith. Ms. Maxwell also request that the Court enter an order requiring that Plaintiff pay
reasonable fees and costs associated with this motion.
Dated: May 9, 2016.
Respectfully submitted,
…
giuffre-maxwell
gov.uscourts.nysd.447706.1231.0
3 pg
…¶ 3(e) (explaining in August 2020 that the objections
would be publicly filed as part of the unsealing process). Intervenors therefore request that all of
the briefings associated with the Does’ objections, as well as the objections themselves, be filed…
giuffre-maxwell
gov.uscourts.nysd.447706.79.2
18 pg
…9:A lld ocu ments id entifyingpassengers,manifests,orflightplans for
any helicopterorplane everowned orcontrolled by you orJ effrey E pstein orany associated
entity from 1999 –present.
RESPONSE:M s.M ax wellobjects to this Requ eston the grou nd s…
giuffre-maxwell
gov.uscourts.nysd.447706.1155.0_2
13 pg
…victims. The Miami Herald’s coverage of Mr. Epstein’s and his associates’ alleged crimes has
nothing to do with consensual sexual preferences and everything to do with the abuse of young
girls, whether that crime was justly prosecuted or…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.6_1
14 pg
…Case
Numerous Publicly Available Police Reports With Redacted Juvenile
Information
In complete contradiction to her legal position in this Motion, Plaintiff and her counsel
have repeatedly filed in public documents associated with this case, police reports from Florida
…
giuffre-maxwell
gov.uscourts.nysd.447706.1204.0
3 pg
…Ultimately, recognizing the extensive litigation that has already occurred, and
appreciative of this Court’s efforts and the burdens associated with this case, Ms. Maxwell decided to
limit her motion to the most consequential testimony.
Case 1:15-cv…
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