giuffre-maxwell
gov.uscourts.nysd.447706.962.0
7 pg
…the
Court explicitly ruled, “[A]ll documents, materials, and information subject to the Protective
Order must be returned to the party who designated its confidentiality as of the date this action
was dismissed.” Sealed Op., at 3 (Nov. 14, 2017) …
giuffre-maxwell
gov.uscourts.nysd.447706.1.0
12 pg
…with the victims about the NPA, the U.S. Attorney’s Office
and Epstein agreed to a “confidentiality” provision in the Agreement barring its disclosure to
anyone—including Epstein’s victims. As a consequence, the victims were not told about…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…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 responses only compelled—because of a strong expectation of
continued confidentiality. See Fed…
giuffre-maxwell
gov.uscourts.nysd.447706.562.1
13 pg
…with the victims about the NPA, the U.S. Attorney’s Office
and Epstein agreed to a “confidentiality” provision in the Agreement barring its disclosure to
anyone—including Epstein’s victims. As a consequence, the victims were not told about…
giuffre-maxwell
gov.uscourts.nysd.447706.139.0
7 pg
…made
to public officers in the performance of the officers’ duties, and for which disclosure would harm
the public interest by removing the protection afforded by confidentiality.”).
4
Ms. Giuffre notes that if she were to produce any one of…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…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 responses only compelled—because of a strong expectation of
continued confidentiality. See Fed…
giuffre-maxwell
gov.uscourts.nysd.447706.24.1
13 pg
…with the victims about the NPA, the U.S. Attorney’s Office
and Epstein agreed to a “confidentiality” provision in the Agreement barring its disclosure to
anyone—including Epstein’s victims. As a consequence, the victims were not told about…
giuffre-maxwell
gov.uscourts.nysd.447706.978.0
27 pg
…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 responses only compelled—because of a strong expectation of
continued confidentiality. See Fed…
giuffre-maxwell
gov.uscourts.nysd.447706.977.0
27 pg
…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 responses only compelled—because of a strong expectation of
continued confidentiality. See Fed…
giuffre-maxwell
gov.uscourts.nysd.447706.1052.0
4 pg
…as practicable after the Notification the Original Parties shall
confer and shall use their best efforts to cause each Non-Party mentioned in the Sealed
Materials to be considered to be served confidentially with the Non-Party Notice.
After objections…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…shall use their best efforts to cause each Non-Party mentioned in the Sealed Materials to
be considered to be served confidentially with a Non-Party Notice approved by the Court.
“Best efforts” entails identifying the most current address available…
giuffre-maxwell
gov.uscourts.nysd.447706.1034.0
16 pg
…shall use their best efforts to cause each Non-Party mentioned in the Sealed Materials to
be considered to be served confidentially with a Non-Party Notice approved by the Court.
“Best efforts” entails identifying the most current address available…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.1
4 pg
…motions.
b. As soon as practicable after the Notification the Original Parties shall confer and
shall use their best efforts to cause each Non-Party to be served confidentially with a
Non-Party Notice approved by the Court. “Best efforts…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.2
4 pg
…motions.
b. As soon as practicable after the Notification the Original Parties shall confer and
shall use their best efforts to cause each Non-Party to be served confidentially with a
Non-Party Notice approved by the Court. “Best efforts…
giuffre-maxwell
gov.uscourts.nysd.447706.1044.0
13 pg
…As soon as practicable after the Notification the Original Parties shall confer and
shall use their best efforts to cause each Non-Party mentioned in the Sealed Materials to
be considered to be served confidentially with the Non-Party Notice…
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