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.447706.1329.0
3 pg
…For the reasons set forth below, the letter-motions
to unseal docket entry 1026-3 are DENIED.
First, docket entry 1026-3 is not an accurate list of
non-party names. Since this filing, the parties have provided the
Court…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.12
11 pg
…Court Order regarding
Forensic Examination of Devices, as follows:
INTRODUCTION
Defense counsel has already run the amended list of search terms proposed by Plaintiff
on each applicable device and as to each email account to which Ms. Maxwell has access…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.29
6 pg
…arem ailsforotherw iseresponsivedocum entsasw ellas
3. W itnessnam es– You believethatsearchterm s124-341,w hicharew itnessnam esbrokenupintofirstand last
nam esfrom yourR ule26 list,relatetoyourR FP num ber5 (“ Alldocum entsrelatingtom assages… ” ).I
represented toyou thatIhavesearchedfortheterm s“ m assage, ” “ m asseur…
giuffre-maxwell
gov.uscourts.nysd.447706.1038.0
2 pg
…agrees to the
Court’s Protocol as written, including the Court’s proposal to review documents by Non-Party in
the order that the Non-Parties are listed on the Non-Party list. Defendant has proposed a number
of changes…
giuffre-maxwell
gov.uscourts.nysd.447706.41.5
18 pg
…or information which will improperly annoy,
embarrass, or oppress any party, witness, or person providing discovery in this case,
Purposes And Limitations Formatted: List Paragraph, Indent: First line:
…
giuffre-maxwell
gov.uscourts.nysd.447706.1029.0
2 pg
…this Court has determined that it will review in
the first instance those motions that were decided by Judge Sweet. Both parties submitted lists of
decided motions to this Court, but Defendant’s list excluded two of those decided motions…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.0_2
65 pg
…and January 26, 2021 (ECF No. 1193),
Plaintiff files the documents ordered unsealed listed in Exhibit F to Defendant’s Reply
Memorandum of Law in Further Support of Objections to Unsealing Sealed Materials Related to
Docket Entries 231, 279, 315…
giuffre-maxwell
gov.uscourts.nysd.447706.320.0
11 pg
…Court Order regarding
Forensic Examination of Devices, as follows:
INTRODUCTION
Defense counsel has already run the amended list of search terms proposed by Plaintiff
on each applicable device and as to each email account to which Ms. Maxwell has access…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.7
6 pg
…arem ailsforotherw iseresponsivedocum entsasw ellas
3. W itnessnam es– You believethatsearchterm s124-341,w hicharew itnessnam esbrokenupintofirstand last
nam esfrom yourR ule26 list,relatetoyourR FP num ber5 (“ Alldocum entsrelatingtom assages… ” ).I
represented toyou thatIhavesearchedfortheterm s“ m assage, ” “ m asseur…
giuffre-maxwell
gov.uscourts.nysd.447706.1188.0
3 pg
…and
151 should be unredacted in those documents and whether the names of other nonparties who have
not objected should be unredacted in those documents.
Accordingly, Plaintiff proposes next addressing the following list of motions that mention
Does 55, 56…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.25
11 pg
…conducted were thorough enough then ensued leading to the instant
submission.
2
searched yet there is no RFP related to those names, nor the vast majority of the other listed first
and surnames.1
By correspondence of July 14, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.1
8 pg
…Order, counsel for Ms. Giuffre sent Defendant’s counsel a letter
requesting that electronic documents, including email, be searched with a detailed list of
proposed search terms. See Declaration of Meredith Schultz (“Schultz Decl.”) at Exhibit 1, June
30, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.17
6 pg
…as .
3. Witness names – You believe that search terms 124-341, which are witness names broken up into first and last
names from your Rule 26 list, relate to your RFP number 5 (“All documents relating to massages…”). I…
giuffre-maxwell
gov.uscourts.nysd.447706.1050.0
12 pg
…email, we're
15 going to include that to give the Non-Parties the greatest
16 opportunity of methods of filing their objections.
17 We had earlier asked the parties to agree on a list of
18 decided motions, and…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…on Monday, August 1, 2016, Ms. Giuffre filed the
list of search terms that Ms. Giuffre believes should be run over Defendant’s data. (DE 323).
2
II. DISCUSSION
At a minimum, the Court should direct Defendant to run…
giuffre-maxwell
gov.uscourts.nysd.447706.1099.0
4 pg
…Having a list of
Non-Parties who have not requested Excerpts (and who therefore do not intend to object to
unsealing) will also be exceedingly helpful to the Original Parties tasked with redacting the names
of Non-Parties who have…
giuffre-maxwell
gov.uscourts.nysd.447706.1021.0
18 pg
…we can separate those out. There are names that appear
25 obviously in Maxwell's non-party list that are not in ours but
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document…
giuffre-maxwell
gov.uscourts.nysd.447706.1300.0
4 pg
…counsel used the incorrect Non-Party pseudonyms to
identify certain Non-Parties because counsel was relying on a prior, outdated version of the Non-
Party list.
5. I therefore submit this amended declaration to replace Plaintiff’s initial declaration
(ECF…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.7
18 pg
…Q. Then there's a category, victim
4 information, and then we have listed, I believe, a
5 total of 17 individuals that the Palm Beach Police
6 Department incident report lists as alleged victims
7 in this case, correct…
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