…active investigations involving Ghislaine Maxwell,” counsel for Defendant unearthed numerous records of such contacts. In the time period just before and during her alleged “sexual slavery” to Jeffrey Epstein and Ghislaine Maxwell, Plaintiff interacted with law enforcement on numerous occasions. …
…a set of redactions from Ms. Maxwell’s counsel other than a few examples she provided via phone during our meet and confer of areas of testimony where she contended there should be additional redactions. We await the Court’s…
…their ability to have the Court perform its review function would contradict the plain terms of the Protocol. Plaintiff knows that many of the Non-Parties timely asserted their privacy interests during the proceedings. These assertions occurred, in many instances…
…as a minor, even though the video had been played publicly for the jury in the underlying trial, and even though a transcript of his statements during that deposition remained publicly available during and after the trial. Id. at 55…
…document basis. Many of these documents have already been reviewed during the review for Does 1 and 2. Case 1:15-cv-07433-LAP Document 1224 Filed 07/28/21 Page 2 of 6 The Honorable Loretta A. Preska…
…Plaintiff’s proposed redactions. Counsel reviewed the proposed redactions to Ms. Maxwell’s 465-page deposition transcript and conferred with Plaintiff’s counsel regarding her proposed redactions during a telephone conference at 1 p.m. today. While undersigned counsel explained…
…compelling reasons. Movant cannot guess what Plaintiff seeks to redact, but none of the bits of information revealed during the hearing raised any significant confidentiality concerns that warranted sealing the courtroom or the order. See Newsday LLC v. Cty. of…
…Dkt. 1195 at 2. Not so. Ms. Maxwell did not lie during her depositions, and the government’s claim that she committed perjury fails for several additional reasons, which Ms. Maxwell has spelled out in her criminal motions. That, however…
…In any event, to the extent the criminal trial’s schedule will be extended due to a break in proceedings (during which Maxwell’s counsel may work on the briefs due in this action), Plaintiff believes that the agreed-to…
…hand. But even if “reasonable reliance on a protective order” could alone outweigh the presumption of public access, Maxwell has failed to demonstrate that she relied on the protective order in answering every single question during her deposition. In fact…
…interests -- counsel 14 against unsealing deposition transcript. Ms. Maxwell argues 15 that her discussion of certain "intimate matters" during that 16 deposition should remain sealed. 17 During this deposition, Ms. Maxwell was asked 18 repeatedly about her own sexual activity…
…the father of her three minor children. These are the types of documents for which confidentiality treatment during pre-trial proceedings is appropriate. B. Defendant’s Challenge of these Materials (and her Joint Defense Partner’s Challenge of Other Materials…
…including the depositions of the infant plaintiffs, reveal intimate details about the sexual and physical abuse these children have been subjected to during their lives.”). Does 55 and 56 have not raised any such countervailing interest here. Even assuming that…
…a compelled deposition. 2 The parties attempted to call the court for a ruling during the deposition but were advised by chambers to “bring any issue to him after the conclusion of the deposition.” See 316- 6 at 79-89. …
…Maxwell’s arguments is meritless, and this Court should once again reject Maxwell’s contentions as unsupported ipse dixits. As it did during last round of unsealing, the Court should instead unseal the documents in their entirety, subject only to …
…4 So we are awaiting a ruling. We believe those 5 individuals should be protected under the Court's protective 6 order and those names kept confidential during the course of 7 this, and it is my understanding that defendants…
…to the world that she “cried rape,”13 and to humiliate her family (including three minor children) by publicizing she was the victim of domestic abuse in 2015. As the Court saw during its in camera review, Defendant and Mr…
…pleadings. Brown, 929 F.3d at 49 n.22. There is no dispute that Ms. Maxwell relied on the Protective Order when she sat for and responded to questions during the July 2016 deposition. Ms. Maxwell opposed the second deposition…
…well-founded here because indeed 9 there are many judicial admissions by the parties to this case 10 during the course of the case where they relied on and asked 11 the Court to endorse and protect the parties and…
…the presumption’s relative weight. Much of the work necessarily falls on the two lead defense counsel for Ms. Maxwell during the district court proceedings, both of whom have many other previously scheduled professional obligations. We respectfully submit this work…
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