giuffre-maxwell
gov.uscourts.nysd.447706.1285.0
6 pg
…any details about her ordeals two decades
ago, she unquestionably continues to experience trauma similar to that of at least one
other Non-Party Doe whose privacy and identity this Court protected with Plaintiff
Virginia Guiffre’s consent. See Doc…
giuffre-maxwell
gov.uscourts.nysd.447706.1286.0
6 pg
…any details about her ordeals two decades
ago, she unquestionably continues to experience trauma similar to that of at least one
other Non-Party Doe whose privacy and identity this Court protected with Plaintiff
Virginia Guiffre’s consent. See Doc…
giuffre-maxwell
gov.uscourts.nysd.447706.148.0
9 pg
…publicly disclosed volumes of information related to her
allegations, to claim that letters or emails from her lawyers or other documents sent to any law
enforcement agency are protected by any privilege. Plaintiff lacks standing to raise the issue and
…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.1_1
13 pg
…Many of them also concern minors and a victim of sexual assault; therefore, they are
protected by various state statutes. Ms. Giuffre requests that this Court maintain the confidentiality
designations over these police reports and direct the Defendant to disclose…
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.447706.1199.4_1
4 pg
…I have several.
First, Florida statutes protect "[a]ny information in a videotaped statement of a minor
who is alleged to be or who is a victim of sexual battery ... which reveals that minor' s identity."
Fla. Stat.§ 119.071…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…Statutes
Plaintiff also cites Colorado statutes which, she claims, support the proposition that her
identity as the victim of domestic violence is protected by Colorado law. It is not. Section 13-
90-107(k),3 is a testimonial privilege statute…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…affirmed by the Second Circuit, found that Ms. Maxwell
failed to identify deposition testimony that “constitute[] personal information which might lead
to annoyance or embarrassment if unsealed” because, inter alia, she “refused to testify as to any
consensual adult activity…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…at least one
press source claimed to “crack” the redactions to identify witnesses and potential testimony by or
3
https://www.npr.org/2020/10/22/926590153/jeffrey-epstein-update-read-the-deposition-that-
ghislaine-maxwell-fought-to-hide
4…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.33
24 pg
…For other providers, no records were produced. Where no
documents were produced, Plaintiff failed to identify the dates and nature of the treatment
received, as requested in the Interrogatory. Id. Plaintiff failed therein to identify any treatment
providers prior to…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.1_2
24 pg
…each category of damages claimed by
the disclosing party—who must also make available for inspection and copying as under Rule 34 the
documents or other evidentiary material, unless privileged or protected from disclosure, on which each
computation is based…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…DE 144 is a lawyer
declaration referencing the exhibits in DE 144-1-7. The declarations accompanying the
various Sealed Materials often identify a Non-Party. The Court may wish to simply redact
all of the Non-Party names from…
giuffre-maxwell
1320-33
24 pg
…For other providers, no records were produced. Where no
documents were produced, Plaintiff failed to identify the dates and nature of the treatment
received, as requested in the Interrogatory. Id. Plaintiff failed therein to identify any treatment
providers prior to…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.8
29 pg
…Florida’s open-records laws. Subsection (2)(h)1.b. provides that “the
identity of a person who is a victim of any sexual offense” (emphasis supplied) is exempt from
the open-records laws. Here, the defense obtained identity-redacted…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.6_1
14 pg
…Statutes
Plaintiff also cites Colorado statutes which, she claims, support the proposition that her
identity as the victim of domestic violence is protected by Colorado law. It is not. Section 13-
90-107(k),3 is a testimonial privilege statute…
giuffre-maxwell
gov.uscourts.nysd.447706.354.0
40 pg
…354 Filed 08/10/16 Page 5 of 40
that Ms. Maxwell has published “numerous” false statements, yet Plaintiff stubbornly refuses to
identify each of these allegedly false statements. Interrogatory No. 6 asked simply that for each
allegedly false statement…
giuffre-maxwell
gov.uscourts.nysd.447706.231.0
23 pg
…For other providers, no records were produced. Where no
documents were produced, Plaintiff failed to identify the dates and nature of the treatment
received, as requested in the Interrogatory. Id. Plaintiff failed therein to identify any treatment
providers prior to…
giuffre-maxwell
gov.uscourts.nysd.447706.1050.0
12 pg
… Good afternoon.
23 MR. KRIEGER: Good afternoon, Judge.
24 THE COURT: Is there any party or non-party who I have
25 missed who wishes to identify himself or herself?
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…the subpoena served on Ms. Ransome seeks documents that are wholly
irrelevant to the underlying action including protected financial information and documents or
communications between Sarah Ransome and her attorneys, which are protected by the attorney-
client privilege and the…