giuffre-maxwell
gov.uscourts.nysd.447706.41.5
18 pg
…abuse.
4. CONFIDENTIAL information shall not be disclosed or used for any purpose
except the preparation and trial of this case and any related matter, including
but not limited to, investigations by law enforcement.
5. CONFIDENTIAL documents, materials, and/or…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.4_1
4 pg
…to law enforcement records involving juveniles is protected by
C.R.S. 19-1-301, et. seq., as "[t]he disclosure of sensitive information carries the risk of
stigmatizing children." C.R.S. 19-1-302. Accordingly, Colorado law protects…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.4
23 pg
…abuse.
4. CONFIDENTIAL information shall not be disclosed or used for any purpose
except the preparation and trial of this case and any related matter, including
but not limited to, investigations by law enforcement.
5. CONFIDENTIAL documents, materials, and/or…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…of civil disputes. 594 F.2d at 295–96. And the Second Circuit there
found that true even in the face of “the public interest in obtaining all relevant evidence required
for law enforcement purposes,” id. at 296, arguably a…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…464 U.S. 501, 510 (1984); the protection of attorney‐client
privilege, Lugosch, 435 F.3d at 125; “the danger of impairing law enforcement or
judicial efficiency,” SEC. v. TheStreet.Com, 273 F.3d 222, 232 (2d Cir. 2001); and…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…464 U.S. 501, 510 (1984); the protection of attorney‐client
privilege, Lugosch, 435 F.3d at 125; “the danger of impairing law enforcement or
judicial efficiency,” SEC. v. TheStreet.Com, 273 F.3d 222, 232 (2d Cir. 2001); and…
giuffre-maxwell
gov.uscourts.nysd.447706.936.0
21 pg
…the Palm Beach state attorney, the FBI and the U.S. Attorney's Office, the negotiations between
those law enforcement agencies and Mr. Epstein's legal defense team, and the ultimate decision
by the U.S. Attorney's Office to…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…Ederi.
3. All Documents containing communications with Jason Richards.
4. All Documents containing communications with law
enforcement agency concerning Virginia Roberts.
5. All Documents reflecting any payment of any money to Virginia
Roberts.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…undue
harassment serving no admissible purpose.
25. Any Documents containing any Communications You have had with any law enforcement
agency.
RESPONSE:
21
In addition to the Preliminary Statement and General Objections, Ransome objects to this
request in that she…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…Any Documents containing any Communications You have had with any law enforcement
agency.
RESPONSE:
21
Case 1:15-cv-07433-LAP Document 1332-8 Filed 01/08/24 Page 23 of 27
In addition to the Preliminary Statement and…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…380 F.3d 110 (2d Cir. 2004) (per curiam)
(witnesses and third parties "possess strong privacy interests,
because being identified as part of a law enforcement
investigation could subject them to 'embarrassme nts and
harassment'" ), "with the deviant and the…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…undue
harassment serving no admissible purpose.
25. Any Documents containing any Communications You have had with any law enforcement
agency.
RESPONSE:
21
In addition to the Preliminary Statement and General Objections, Ransome objects to this
request in that she…
giuffre-maxwell
gov.uscourts.nysd.447706.978.0
27 pg
…464 U.S. 501, 510 (1984); the protection of attorney‐client
privilege, Lugosch, 435 F.3d at 125; “the danger of impairing law enforcement or
judicial efficiency,” SEC. v. TheStreet.Com, 273 F.3d 222, 232 (2d Cir. 2001); and…
giuffre-maxwell
gov.uscourts.nysd.447706.1118.0
21 pg
…# 222). There can be no information in this unrelated defamation action that is
“critical to the USVI’s law enforcement action,” given Mr. Epstein’s refusal to respond to
questions when compelled to do so in a deposition years ago…
giuffre-maxwell
gov.uscourts.nysd.447706.977.0
27 pg
…464 U.S. 501, 510 (1984); the protection of attorney‐client
privilege, Lugosch, 435 F.3d at 125; “the danger of impairing law enforcement or
judicial efficiency,” SEC. v. TheStreet.Com, 273 F.3d 222, 232 (2d Cir. 2001); and…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.0
35 pg
…yet expired.
Note: The deponent is not on the Non-Party notification list
because he is a law enforcement officer.
258-5 Unseal but redact medical information and addresses.
258-6 Unseal but redact medical information and addresses.
258-7…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…remain
sealed. However, nothing set forth herein precludes any party from communicating, publicly or
otherwise, including to law enforcement agencies, so long as such disclosures do not reveal the
contents of the Sealed Materials. A party is, therefore, free and…
giuffre-maxwell
gov.uscourts.nysd.447706.993.0
28 pg
…a
“danger of impairment of law enforcement.” Id. To the contrary, it would be in the furtherance
of law enforcement efforts if the Court were to make information available for each law
enforcement agency to assess if any prosecution is…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.17
13 pg
…preparation to litigate Ms. Giuffre’s factual allegations, the parties
sought and obtained from each other and non-parties a wide range of highly sensitive, personal
and confidential information about themselves and non-parties.
This Protective Order. To facilitate disclosures…
giuffre-maxwell
gov.uscourts.nysd.447706.957.0
13 pg
…preparation to litigate Ms. Giuffre’s factual allegations, the parties
sought and obtained from each other and non-parties a wide range of highly sensitive, personal
and confidential information about themselves and non-parties.
This Protective Order. To facilitate disclosures…
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