giuffre-maxwell
gov.uscourts.nysd.447706.1083.0
3 pg
…1077) that the parties redact from those
pleadings to be unsealed three categories: 1) “personal identifying information as to any
person mentioned in the documents,” 2) “the names of nonparties other than Does 1 and 2,”
and 3) “other portions…
giuffre-maxwell
gov.uscourts.nysd.447706.1080.0
2 pg
…that “personal identifying information as to any person mentioned in the
documents and the names of nonparties other than Does 1 and 2 and other portions related to such
nonparties’ specific conduct will be redacted from the materials being unsealed…
giuffre-maxwell
gov.uscourts.nysd.447706.1099.0
4 pg
…in support of an
Original Party’s objections to unsealing.
The parties have been unable to reach agreement on the following proposals:
First, Plaintiff proposed reviewing the remaining set of motions that mention Doe 1 or Doe
2: 231, 279…
giuffre-maxwell
gov.uscourts.nysd.447706.1220.0
17 pg
…5 As with the last round of unsealed materials, the
6 documents at issue here, unless otherwise mentioned, were
7 submitted in connection with discovery motions decided by Judge
8 Sweet. The parties and nonparties dispute whether certain of
9…
giuffre-maxwell
gov.uscourts.nysd.447706.1242.0
9 pg
…redactions be narrowly tailored to address the countervailing interests Doe 54
raised.
II. Does 55 and 56 Have Not Rebutted the Presumption in Favor of Public Access.
Does 55 and 56 are mentioned in Docket Entries 204-2, 212-2…
giuffre-maxwell
gov.uscourts.nysd.447706.1284.0
17 pg
…who have not filed
15 objections.
16 We are now still in the first phase. As I mentioned,
17 upon consideration today are the objections of the second set
18 of aid of the 16 nonparty objectors: Does 12, 28…
giuffre-maxwell
gov.uscourts.nysd.447706.1283.0
17 pg
…who have not filed
15 objections.
16 We are now still in the first phase. As I mentioned,
17 upon consideration today are the objections of the second set
18 of aid of the 16 nonparty objectors: Does 12, 28…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.35
10 pg
…never “testified that Defendant
procured underage girls for Epstein.” (Reply at 4) To the contrary, he testified that all of the
underage girls he interviewed never mentioned Ms. Maxwell at all.
These are but a few of the misrepresentations of…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.23
10 pg
…never “testified that Defendant
procured underage girls for Epstein.” (Reply at 4) To the contrary, he testified that all of the
underage girls he interviewed never mentioned Ms. Maxwell at all.
These are but a few of the misrepresentations of…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…a
requirement, however, and in the intervening years courts in this District have presided over
numerous Epstein-related cases and handled sealing (and unsealing) motions without soliciting
objections from third parties who were mentioned in the documents. See, e.g…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.27
6 pg
…Certified Realtime 7 A Hi.
8 Reporter and Notary Public within Colorado. 8 Q As we mentioned off the record, my name is
9 9 Laura Menninger --
*******
10 …
giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…Except as to Documents Describing Sexual
Abuse.
Doe 28 is mentioned in 25 documents.3 The totality of Doe 28’s objection is that unsealing
of the materials at issue “would be detrimental to [Doe 28’s] wellbeing as [they…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…The Court Should Unseal Portions of Docket Entries the Second Circuit Already
Released. .................................................................................................................................... 6
III. The Court Should Unseal Portions of Documents Mentioning Doe 1 and Doe 2. ... 6
IV. …
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…Clinton were included in her initial Rule 26 disclosures served on November 11, 2015 and two of
the six were specifically mentioned in Plaintiff’s Complaint.
Finally, the fact that witness Rinaldo Rizzo had a deposition re-scheduled from April…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…There are a few groups of people, his office in New
York and I guess --
***
Q. Okay. The other people mentioned as co-conspirators are Sarah Kellen, Adriana Ross, and
Nadia Marcinkova. So we'll get to them in a…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.14
9 pg
…That is prejudicial. It is Defendant who has behaved
improperly in repeated depositions, and Plaintiff should not be required to pay for a special
master.
A final point needs to be mentioned. As recounted in the background section above, the
…
giuffre-maxwell
gov.uscourts.nysd.447706.1069.0
25 pg
…heard on reliance?
4 All right. The next question I have is: How are we
5 to protect the interests of the nonparties or third parties who
6 either produced materials or were mentioned in the materials?
7 MR. COOPER:…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…Giuffre is copied on the message. Ms. Churcher mentions
Professor Dershowitz as one of Epstein’s lawyers, together with Kenneth Starr, but not as an
abuser:
Hi Jarred
Hopefully you have Virginia' s book pitch by now.
She has some…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…re referring to.
3 "Q. So was there -- during your time, was there no other --
4 you mentioned information on a computer. Was there any
5 hard-copy document you would refer to to find someone's number?
6 "A…
giuffre-maxwell
gov.uscourts.nysd.447706.1154.0_5
3 pg
…trauma and did not want to be involved in the proceedings at all. Doe
#84’s name was mentioned in some of the sealed summary judgment pleadings, and the
Second Circuit sua sponte redacted the name and the deposition testimony…
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