giuffre-maxwell
gov.uscourts.nysd.447706.1258.0
3 pg
…and unredacted any and all documents that identify the men who abused the girls trafficked
by Jeffrey Epstein and Defendant Maxwell (“the Epstein Client List”).
Sealing those documents violates the rights of the press and of the people at large…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…Record ......................................................................... 13
2.2.1 The Compelling Reason Standard Applies to the Documents at Issue ................. 14
2.2.2 There is Neither a “Compelling Reason” nor “Good Cause” to Seal the Epstein
Client List ..................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.9
6 pg
…Devonshires Solicitors LLP and registration number 619881. This Firm does not accept
service by electronic mail or facsimile. A list of members is open to inspection at the address below.
Devonshires Solicitors, 30 Finsbury Circus, London EC2M 7DT tel +44 …
giuffre-maxwell
gov.uscourts.nysd.447706.1330.6
10 pg
…with the State Attomc,y's Office prior to entering
into those agreements.
7. The United States shall provide Epstein's attorneys with a list of
individuals whom it has identified as victims, as defined in 18 U.S.C.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.8
12 pg
…yourself, Ghislaine Maxwell and Sarah Kellen had access to a
master of list of underage minor females names and phone numbers so they could
be called for the purpose of coming to Jeffrey Epstein’s house to be sexually
molested…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.0
35 pg
…Accordingly, Maxwell bears the burden of identifying
“with specificity competing and compelling interests in closure” and that “those interests outweigh
1
The Brown minimal redactions encompass: (1) “personally identifying information such as
personal phone numbers, contact lists, birth dates, and…
giuffre-maxwell
gov.uscourts.nysd.447706.1213.0
18 pg
…15-cv-07433-LAP Document 1213 Filed 02/12/21 Page 11 of 18
be rejected. Maxwell herself drafted the decided motions list, selected the motions to be included,
and conferred extensively with Plaintiff about the contents of that list…
giuffre-maxwell
gov.uscourts.nysd.447706.89.0
10 pg
…specifically communicates this fact by listing all of the attorneys
7
Case 1:15-cv-07433-LAP Document 89 Filed 04/10/16 Page 8 of 10
working on the above-captioned matter -- a list that includes both Professor…
giuffre-maxwell
gov.uscourts.nysd.447706.946.0_1
14 pg
…asked the Court to defer to
the parties' judgment on confidentiality but it also allowed for
unilateral designation of an exhibit as protected material, and it did
not list specific documents, or delineate the kinds of documents
contemplated for protection…
giuffre-maxwell
1320-8
12 pg
…yourself, Ghislaine Maxwell and Sarah Kellen had access to a
master of list of underage minor females names and phone numbers so they could
be called for the purpose of coming to Jeffrey Epstein’s house to be sexually
molested…
giuffre-maxwell
gov.uscourts.nysd.447706.160.0
12 pg
…yourself, Ghislaine Maxwell and Sarah Kellen had access to a
master of list of underage minor females names and phone numbers so they could
be called for the purpose of coming to Jeffrey Epstein’s house to be sexually
molested…
giuffre-maxwell
gov.uscourts.nysd.447706.436.0
15 pg
…341 (S.D.N.Y. 2003) (granting modification of protective order where stipulated
order “allowed for unilateral designation of an exhibit as protected material, and it did not list
specific documents, or delineate the kinds of documents, contemplated for protection”…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.1
8 pg
…Maxwell her
credibility, said Boies, who listened to the hearing remotely.
‘To mount a ‘blame the victim’ defense, particularly in today’s world and trying
to blame these girls for what happened is so contrary to the evidence, is so
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.15
6 pg
…Would you agree with me, ma'am, that you
13 instruct the witness not to answer based on her 13 have seen this passenger manifest, listed as
14 Fifth Amendment privilege. 14 Exhibit 3, in the past?
15 THE WITNESS…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…had with these men so that he could potentially blackmail them.
The Government was well aware of Jane Doe #3 when it was negotiating the NPA, as it
listed her as a victim in the attachment to the NPA. Moreover…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…prosecuting the criminal case has not yet disclosed any details concerning Rule 404(b)
evidence that it might seek to introduce in the criminal case, nor has either side disclosed their
witness lists or exhibits. Discovery is not yet complete…
giuffre-maxwell
gov.uscourts.nysd.447706.364.0
32 pg
…make it. This lawsuit concerns the veracity of Ms.
Giuffre’s allegations of sexual abuse—allegations of which Professor Dershowitz has been a
repeated target.
Both parties
have listed Professor Dershowitz as a key witness in this case, Dershowitz Decl…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…purporting to
challenge Epstein's plea agreement. Giuffre's joinder motion
(the "Joinder Motion") included numerous details about Giuffre's
sexual abuse and listed the perpetrators of her abuse. Giuffre
repeatedly named Maxwell in the Joinder Motion as being
personally…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…had with these men so that he could potentially blackmail them.
The Government was well aware of Jane Doe #3 when it was negotiating the NPA, as it
listed her as a victim in the attachment to the NPA. Moreover…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.15
43 pg
…L _l) ' • . .
I. (a) PLAINTIFFS Virginia L. Giuffre DEFENDANTS Jeffrey Epstein -------
(b) County of Residence of Ftrst Listed Pla111t1ff …
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