giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…24, 2015 3:36 AM
To: G Max; Ph ilip Ba rden
Subject: VR cried rape - prior case dismissed as pmsecutors found her 'not credible'
Ghislaine
Some helpful leakage ...
Defendant has been liberal with her own confidentiality designations. In fact…
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…No. 1108. The Parties met and conferred on July 26, and discussed
ways in which the sealing process can proceed more efficiently. The Parties therefore present the
following options to the Court.
Plaintiff’s Proposal
At the July 1, 2021…
giuffre-maxwell
gov.uscourts.nysd.447706.1136.0_5
2 pg
…the
materials. The Court provided details of those additional
redactions to the parties by email. As the Court has discussed in
prior orders, the relevant materials shall be posted on the docket
no later than 9:00 a.m. on…
giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…For reasons having to do with the legal bases for sealing and redacting non-judicial and
judicial documents, discussed later in this letter, this was not a project that could be
performed by non-lawyers or by lawyers who did…
giuffre-maxwell
gov.uscourts.nysd.447706.1134.0_5
2 pg
…able to review
Plaintiff’s proposed redactions, however, and each concluded that they sufficiently obscured
information such that the public would not be able to identify the nonparty being discussed. In
any event, Maxwell’s vague and ambiguous reference to…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…of the materials at issue here will unfairly prejudice Ms.
Maxwell’s rights to a fair trial by poisoning any venire and influencing witness testimony. For
reasons discussed below, the Court should decline to unseal the identified Sealed Items.
I…
giuffre-maxwell
gov.uscourts.nysd.447706.1248.0
6 pg
…referenced as having some affiliation with or knowledge of Jeffrey Epstein and Ghislaine Maxwell,
on the other. As discussed in more detail below, the former group can maintain privacy by narrowly
redacting information that would identify those who have not…
giuffre-maxwell
gov.uscourts.nysd.447706.1049.0
91 pg
…UNSEALED
15, 16, 16‐
1, 23, 24,
14 Defendant's Motion to Dismiss 12.1.15 37 2.29.16
25, 26, 26‐
1, 29…
giuffre-maxwell
gov.uscourts.nysd.447706.892.0
11 pg
…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 dismiss the complaint of
plaintiff Virginia L …
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…172, Maxwell contends that all redactions should remain in place
because the document contains “references” to her deposition testimony and a Non-Party’s
deposition testimony, and she cites the same countervailing interests discussed in Part IV, supra.
Maxwell Mem…
giuffre-maxwell
gov.uscourts.nysd.447706.1021.0
18 pg
… Then, of course, as
20 we discussed, as is discussed in the proposed revised protocol,
21 then after the non-parties respond -- if they do -- then you
22 would have an opportunity to put in your countervailing
23 interests. So…
giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…2019) (Kaplan, J.) (just because “some information relating to the documents
in question already has been discussed on the public record or reported in the media does not
1
CRL § 50-b(1) requires public officials to ensure that “[t…
giuffre-maxwell
gov.uscourts.nysd.447706.1284.0
17 pg
…just because "some information relating to
4 the documents in question already has been discussed on the
5 public record or reported in the media does not mean that the
6 concerned third parties have lost any remaining privacy
7…
giuffre-maxwell
gov.uscourts.nysd.447706.1283.0
17 pg
…just because "some information relating to
4 the documents in question already has been discussed on the
5 public record or reported in the media does not mean that the
6 concerned third parties have lost any remaining privacy
7…
giuffre-maxwell
gov.uscourts.nysd.447706.1087.0
4 pg
…the Court notes that Ms. Maxwell has
primarily raised issues related to nonparties named in Doe 1’s and
Ms. Maxwell’s depositions. As discussed in the Court’s July 29
Order (dkt. no. 1079), those deposition transcripts and documents…
giuffre-maxwell
gov.uscourts.nysd.447706.949.0
31 pg
…file them.
15 Someone could file a complaint making a bunch of
16 allegations just to get it in a newspaper and the allegations
17 aren't true and they take a dismissal after the newspaper
18 humiliates a defendant…
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.447706.551.0
17 pg
…appropriate to protect not only its own interest in covering this case, but
also to protect the interests of the public at large.
2.0 Analysis
As discussed herein, there is no proper basis to deny Movant access to the…
giuffre-maxwell
gov.uscourts.nysd.447706.833.0
4 pg
…book. This reference to evidence is otherwise discussed in publicly available articles
and even the public docket entries in this case.
2
Case 1:15-cv-07433-LAP Document 833 Filed 04/05/17 Page 3 of 4
Similarly…
giuffre-maxwell
gov.uscourts.nysd.447706.1204.0
3 pg
…her). If the
government’s conduct was unlawful and unconstitutional, as Ms. Maxwell contends it was,
Judge Nathan can suppress the evidence and dismiss the perjury counts, as Ms. Maxwell
argues she should.1 There is nothing improper, as the…
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