giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
… Intervenors’ First Proposition of Law: For minor victims of sexual abuse, “redactions
should be applied sparingly to shield only information that would identify those who
have not already been publicly identified.” DE 1248, at 2.
The Reality: Courts routinely seal…
giuffre-maxwell
gov.uscourts.nysd.447706.773.4
5 pg
…that has allowed Fort
Lauderdale lawyer Bradley Edwards’ claim of malicious prosecution
against Epstein to proceed.
President Trump “has been identified as an individual who may have
information relating to these allegations,” said Edwards’ West Palm Beach
attorney Jack Scarola…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…Court of the 15th Cir. for Palm Beach County) ("Epstein v. Edwards"). The
Supplemental responses also identified the pleadings, discovery responses and depositions in
twenty-four civil proceedings in which Dersbowitz's client, Jeffrey Epstein, is named as a party…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.1
8 pg
…otherwise
prejudice the due administration of justice.
To avoid any confusion this Court identified seven “subject matters” that “presumptively
involve a substantial likelihood that their public dissemination will interfere with a fair trial or
otherwise prejudice the due administration of…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.1_1
13 pg
…therein.
I. BACKGROUND
In a March 21, 2016, meet-and-confer call, Defendant’s counsel specifically referenced
certain police reports wherein Ms. Giuffre was identified as a victim. On April 14, 2016, Ms. Giuffre
issued requests for production, seeking the…
giuffre-maxwell
gov.uscourts.nysd.447706.1240.0
5 pg
…810
F. Supp. 2d 616, 621–22 (S.D.N.Y. 2011). Those factors and the harm of disclosure must be
identified with specificity. Lytle, 810 F. Supp. 2d at 621–22.
As set forth below, the Does have failed…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.22
22 pg
…122864. M STATED, EARLIER IN THE DAY SHE
ONE OF THE OCCUPANTS HOME THAT THE OCCUPANT WAS RAPED APPROX!-"
MATELY AGO AT AN UNKNOWN LOCATION IN LOXAHATCHEE.
IDENTIFIED THE VIqTIM AS WHITE FEMALE, n.
I THEN MET WI…
giuffre-maxwell
gov.uscourts.nysd.447706.751.10
4 pg
…sexual contact ever took place
between the pair as "false and hurtful to me."
Interview request
The woman, identified by Buckingham Palace as Virginia Roberts, first named the prince in a civil motion filed
December 30 in the U.S…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…trial. Ms. Maxwell’s responses to Plaintiff’s Interrogatories
are based on information currently known to her and are given without waiving Ms. Maxwell’s
right to use evidence of any subsequently discovered or identified facts, documents or
communications. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.10
23 pg
…LAP Document 1328-10 Filed 01/05/24 Page 4 of 23
Confidential
Page 2 0
1 G. Maxwell - Confidential
2 anyone in any of Mr. Epstein ' s five homes
3 that you have identified?
4 A. Yes .
5 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.17
25 pg
…trial. Ms. Maxwell’s responses to Plaintiff’s requests are
based on information currently known to her and are given without waiving Ms. Maxwell’s right
to use evidence of any subsequently discovered or identified facts, documents or
communications. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1067.0
10 pg
…the alleged countervailing interests that are insufficient to
outweigh the presumption of access to these judicial documents.
As set forth in detail below, there is no basis identified in the Objections for the Court to
continue sealing Dkt. Entries 143…
giuffre-maxwell
gov.uscourts.nysd.447706.1248.0
6 pg
…JPMorgan Chase, 810 F. Supp. 2d 616, 621–22 (S.D.N.Y.
2011). Facts allegedly supporting sealing and the harm of disclosure must be identified with
specificity. Lytle, 810 F. Supp. 2d at 621–22. It does not appear…
giuffre-maxwell
gov.uscourts.nysd.447706.24.3
3 pg
…the documents, a woman identified as Jane Doe 3 says Ms Maxwell asked her to visit Epstein’s
Florida mansion when she was 15 years old.
The document says: “Epstein and Maxwell turned it into a sexual encounter, as they…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…for joinder. As the Court is aware, on July 7, 2008, a young
woman identified as Jane Doe No. 1 filed an emergency petition to enforce her rights under the
Crime Victims’ Rights Act (CVRA), 18 U.S.C. § 3771…
giuffre-maxwell
gov.uscourts.nysd.447706.201.0
5 pg
… Case 1:15-cv-07433-RWS Document 201 Filed 06/13/16 Page 2 of 5
identified individuals who may have relevant information about the matters at issue in this case.
Certain of those individuals have been the subject…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.10
23 pg
…LAP Document 1327-10 Filed 01/05/24 Page 4 of 23
Confidential
Page 2 0
1 G. Maxwell - Confidential
2 anyone in any of Mr. Epstein ' s five homes
3 that you have identified?
4 A. Yes .
5 Q…
giuffre-maxwell
1320-17
25 pg
…trial. Ms. Maxwell’s responses to Plaintiff’s requests are
based on information currently known to her and are given without waiving Ms. Maxwell’s right
to use evidence of any subsequently discovered or identified facts, documents or
communications. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.408.0
13 pg
…two additional victims to
the case, including Ms. Virginia Giuffre (who was identified in court pleadings as “Jane Doe No.
3”). Edwards and I sought to have her added to the case via stipulation, which would have
avoided the need…
giuffre-maxwell
gov.uscourts.nysd.447706.26.0
3 pg
…Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is
being served this day on the individuals identified below via transmission of Notices of Electronic
Filing generated by CM/ECF.
Laura A. Menninger…
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