giuffre-maxwell
gov.uscourts.nysd.447706.986.0
60 pg
…Court
500 Pearl Street
New York, NY 10007
Re: Giuffre v. Maxwell,
Case No. 15-cv-07433-LAP
Dear Judge Preska:
Plaintiff submits the following categories of documents pursuant to the Court’s Order of
September 5, 2019. Dkt. 982…
giuffre-maxwell
gov.uscourts.nysd.447706.1188.0
3 pg
…more efficiently without becoming unduly burdensome. The Original Parties therefore
present the following options to the Court.
Plaintiff’s Proposal
Plaintiff proposes beginning to address Non-Party objections in the next round of
unsealing, rather than first finishing the remaining…
giuffre-maxwell
gov.uscourts.nysd.447706.1070.0
1 pg
…such NOTICE is filed, the transcript may be made remotely electronically
available to the public without redaction after ninety (90) calendar days.
This process may only be used to redact the following personal data identifiers: Social Security
numbers; dates of…
giuffre-maxwell
gov.uscourts.nysd.447706.1255.0
1 pg
…such NOTICE is filed, the transcript may be made remotely electronically
available to the public without redaction after ninety (90) calendar days.
This process may only be used to redact the following personal data identifiers: Social Security
numbers; dates of…
giuffre-maxwell
gov.uscourts.nysd.447706.1099.0
4 pg
…1096.
As to streamlining the process, the parties have agreed upon the following changes to the
Protocol:
First, to speed up the unsealing process and to minimize the number of Non-Party names
that need to be redacted from future…
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…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, hearing…
giuffre-maxwell
gov.uscourts.nysd.447706.1197.0_1
1 pg
…such NOTICE is filed, the transcript may be made remotely electronically
available to the public without redaction after ninety (90) calendar days.
This process may only be used to redact the following personal data identifiers: Social Security
numbers; dates of…
giuffre-maxwell
gov.uscourts.nysd.447706.710.0
1 pg
…Case No.: 15-cv-07433-RWS
Dear Judge Sweet:
I write to request withdrawal of DE 707 and DE 708 (for a scrivener’s error) and
submit the following corrected letter motion.
As a follow up to the March 9…
giuffre-maxwell
gov.uscourts.nysd.447706.1022.0
1 pg
…such NOTICE is filed, the transcript may be made remotely electronically
available to the public without redaction after ninety (90) calendar days.
This process may only be used to redact the following personal data identifiers: Social Security
numbers; dates of…
giuffre-maxwell
gov.uscourts.nysd.447706.32.0
1 pg
…such NOTICE is filed, the
transcript may be made remotely electronically available to the public without redaction after
ninety (90) calendar days.
This process may only be used to redact the following personal data identifiers: Social-
Security numbers; dates of…
giuffre-maxwell
gov.uscourts.nysd.447706.1052.0
4 pg
…NY 10007
Re: Giuffre v. Maxwell,
Case No. 15-cv-7433-LAP
Dear Judge Preska,
The Original Parties jointly write to seek clarification of the following parts of the Protocol
for Unsealing Decided Motions, ECF No. 1044:
at a time…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.0
3 pg
…ECF No. 1230 at 3.
Plaintiff’s Position
On October 5, 2021, pursuant to the Court’s order, Plaintiff proposed via email that the
following eight non-party objectors that should be briefed first: Does 17, 53, 54, 55, 56…
giuffre-maxwell
gov.uscourts.nysd.447706.1349.0
31 pg
…2025
DECIDED: JULY 23, 2025
________________
Before: CABRANES, RAGGI, and PÉREZ, Circuit Judges.
________________
Following this court’s remand in Brown v. Maxwell, 929 F.3d 41 (2d
Cir. 2019)…
giuffre-maxwell
gov.uscourts.nysd.447706.813.0
3 pg
…3 of 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 29th day of March, 2017, I served the attached document
via CM/ECF and e-mail to the following counsel of record.
Laura A. Menninger, Esq.
Jeffrey Pagliuca…
giuffre-maxwell
gov.uscourts.nysd.447706.933.0
3 pg
…3 of 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 28th day of November, 2017, I served the attached
document via CM/ECF and e-mail to the following counsel of record.
Laura A. Menninger, Esq.
Jeffrey Pagliuca…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…process and afford persons identified or otherwise interested in the
Sealed Materials the opportunity to participate in the Court’s individualized review, the Court
adopts the following protocol.
1. Non-Parties List: Plaintiff Virginia Giuffre and Defendant Ghislaine Maxwell
(collectively…
giuffre-maxwell
gov.uscourts.nysd.447706.1154.0_5
3 pg
…3(f) of the Protocol
(DE 1108), this Court held the following:
A Non-Party’s participation in this protocol is optional….Non-Parties are
under no obligation to object, and a Non-Party’s decision not to do…
giuffre-maxwell
gov.uscourts.nysd.447706.1318.0
3 pg
…1313. On October 27, 2023, the Court entered the following
endorsement:
Doe 107 shall, by November 22, 2023, submit to the Court for in
camera review an affidavit supporting her assertion that she
faces a risk of physical harm in…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…subpoena demonstrates
that Defendant is not even seeking documents relevant to the matter before this Court, and is
instead attempting to obtain backdoor discovery for other actions.
Ms. Ransome’s responses are subject to the following qualifications, explanations, and
objections…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.1
4 pg
…process and afford persons identified or otherwise interested in the
Sealed Materials the opportunity to participate in the Court’s individualized review, the Court
adopts the following protocol.
1. Non-Parties List: Plaintiff Virginia Giuffre and Defendant Ghislaine Maxwell
(collectively…