giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…Specifically, each
notification should identify (1) the Doe identifier number; (2) how the Doe is connected to the case
(e.g. victim, alleged perpetrator, witness, someone named in flight logs, or an individual whose
association has been publicly reported, etc.)…
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.447706.1253.0
12 pg
…3d 612 (S.D.N.Y. 2019), is distinguishable. That
case was about the unsealing of materials related to searches conducted by the FBI and in
connection with an investigation. Id. at 617-18. With respect to the non-parties…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…21 MR. PAGLIUCA: This is not a document that has been
22 produced by the plaintiffs, and it has never been labeled as
23 confidential in connection with this case.
24 MS. McCAWLEY: Sorry. I was concerned about that.
25…
giuffre-maxwell
gov.uscourts.nysd.447706.1080.0
2 pg
…23, 2020, hearing, the Court held that Defendant “fail[ed] to rebut the
presumption of public access to the motions at issue and the documents filed in connection with
those motions. Accordingly, those papers shall be unsealed.” July 23, 2020…
giuffre-maxwell
gov.uscourts.nysd.447706.977.2
1 pg
…the district court is better suited to
the task. As the Court’s opinion recognizes in connection with the remaining
sealed materials, the district court is better positioned to communicate with the
parties and any nonparties whose privacy interests might…
giuffre-maxwell
gov.uscourts.nysd.447706.968.1
1 pg
…the district court is better suited to
the task. As the Court’s opinion recognizes in connection with the remaining
sealed materials, the district court is better positioned to communicate with the
parties and any nonparties whose privacy interests might…
giuffre-maxwell
gov.uscourts.nysd.447706.1196.0
32 pg
… By its terms, this rule applies to
21 "lawyers or law firms, "government agents and police officers,"
22 "in connection with pending or imminent criminal litigation
23 with which they are associated. Id. It is not clear to the
24…
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.447706.1248.0
6 pg
…therefore, limited to the public
information.
Case 1:15-cv-07433-LAP Document 1248 Filed 04/01/22 Page 3 of 6
in connection with the abuse. The latter group has no privacy or other countervailing interests that
can…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…and therefore, at most,
begin with a presumption of public access “somewhat lower than the presumption applied to
material introduced at trial, or in connection with dispositive motions such as motions for
dismissal or summary judgment.” Brown v. Maxwell, 929…
giuffre-maxwell
gov.uscourts.nysd.447706.892.0
11 pg
…b) to intervene in this action and to
modify the protective order entered in this action in order to
unseal particular documents submitted in connection with the
motion of defendant Ghislaine Maxwell (" Maxwell " or the
"Defendant") for summary judgment to…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…are subject to at least some presumption of public
access.” Brown, 929 F.3d at 50. “[A]ll documents submitted in connection with, and relevant to,
such judicial decision-making” are also entitled to a presumption of public access. Id.…
giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…party. If a party or non-
party provides information in connection with a lawsuit in reasonable reliance upon a
Case 1:15-cv-07433-LAP Document 1020 Filed 01/17/20 Page 5 of 7
Honorable Loretta A. Preska…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…And, those concerns, as well as the other
countervailing interests could not have been raised or decided in connection with Ms. Maxwell’s
July 2016 deposition in the Second Circuit’s October 20, 2020 order because no portion of Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.0
35 pg
…undisclosed. Because Maxwell’s deposition
testimony is a judicial document that she herself submitted in connection with a request for judicial
1
Case 1:15-cv-07433-LAP Document 1156 Filed 11/19/20 Page 6 of 19
relief…
giuffre-maxwell
gov.uscourts.nysd.447706.1025.0
17 pg
…if so, to prepare my objection; (b) I am prohibited from disclosing the Excerpts to any
person other than a lawyer representing me in connection with this proceeding.
3. I acknowledge that if I want to review the Excerpts, I…
giuffre-maxwell
gov.uscourts.nysd.447706.949.0
31 pg
…of the documents that have been submitted in
14 connection with this case are highly sensitive confidential
15 documents that relate to very private matters of many
16 individuals.
17 Everyone associated with this case relied heavily on
18 this…
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