giuffre-maxwell
gov.uscourts.nysd.447706.1328.33
3 pg
…and it is my understanding that you represent Ghislaine Maxwell.
I am working on an article about the legal fallout from the Jeffrey Epstein case.
I anticipate mentioning the lawsuit filed earlier this year by Virginia Roberts Guiffee against Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.27
3 pg
…and it is my understanding that you represent Ghislaine Maxwell.
I am working on an article about the legal fallout from the Jeffrey Epstein case.
I anticipate mentioning the lawsuit filed earlier this year by Virginia Roberts Guiffee against Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1034.0
16 pg
…2019).
4. Notice of Appellate Rights: The Protocol will include the
provision notifying non-parties of their appellate rights
with respect to any decision to unseal a document mentioning
their name. That provision will provide that “[a]n order
from…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.9
6 pg
…and it is my understanding that you represent Ghislaine Maxwell.
I am working on an article about the legal fallout from the Jeffrey Epstein case.
I anticipate mentioning the lawsuit filed earlier this year by Virginia Roberts Guiffee against Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.992.0
5 pg
…respect to such evidentiary and discovery
matters can cause substantial harm” and that such motions “are therefore of value to those
monitoring the federal court,” rendering them “subject to at least some presumption of public
access.” 929 F.3d at…
giuffre-maxwell
gov.uscourts.nysd.447706.1215.0
13 pg
…case. The Court should not allow such callous abuse of a First Amendment right,
particularly as there is no merit to Dershowitz’s claim (Br. at 21) that ‘public monitoring has an
important role to play here.’” Id. at 19…
giuffre-maxwell
gov.uscourts.nysd.447706.1253.0
12 pg
…Access.
In their reply submission, Doe 144 again presents three principal reasons that the Court
should not unseal material mentioning them: (1) that the presumption of public access here is low;
(2) that any public value of the material is…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.1
7 pg
…redactions of yet-to-be-noticed Non-Party names (if any)
Unseal in full (no applicable Brown minimal redactions or yet-
165-11
to-be-noticed Non-Party names)
Unseal portions mentioning Doe 1 or Doe 2 (pg…
giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…The
paper’s value to “those monitoring the federal courts” would be “negligible,” id.,
since the federal court would have exercised no judicial authority in connection with
the paper.
3
Case 1:15-cv-07433-LAP Document 996 Filed…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…Maxwell
anticipates more extensive briefing on this issue in support of Mr. Epstein’s Motion to Quash, a
few facts bear mentioning here:
x Ms. Maxwell was the employee of Mr. Epstein --in the 1990s -- not the other way
around…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…14
great weight is given to documents that are material to particular judicial decisions and thus
critical to ‘determining litigants’ substantive rights -- conduct at the heart of Article III -- and . . .
public monitoring of that conduct.’” All Funds, 643 F. Supp…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…50).
A. Non-Response from Does 1 and 2 Not Dispositive of Countervailing Interests
Plaintiff argues that all documents mentioning Does 1 and 2 should be released because
neither requested excerpts nor interposed any objection. She also claims that some…
giuffre-maxwell
gov.uscourts.nysd.447706.1237.0
20 pg
…See Amodeo,
71 F.3d at 1051.
Accordingly, given the public’s interest in monitoring the judicial functions overseeing this
case, that with important and national ramifications that have been widely reported in the media,
the deposition material should be…
giuffre-maxwell
gov.uscourts.nysd.447706.1289.0
3 pg
…3
Finally, Doe 171 asks that the Court redact portions of the November 18, 2022, hearing
transcript—specifically the positions mentioning her. There is no basis, however, for sealing the
transcript to a public hearing that was attended by several…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…of the presumption of public access by evaluating “the role of the material at issue in the
exercise of the Article III judicial power and the resultant value of such information to those
monitoring the federal courts.” United States v…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…Maxwell
anticipates more extensive briefing on this issue in support of Mr. Epstein’s Motion to Quash, a
few facts bear mentioning here:
Ms. Maxwell was the employee of Mr. Epstein --in the 1990s -- not the other way
around…
giuffre-maxwell
gov.uscourts.nysd.447706.1213.0
18 pg
…criminal proceedings, Maxwell instead
criticizes the court-ordered unsealing process generally, claiming that the unsealing process has
been weaponized against her and that the media has not “served the function of ‘monitoring the
federal courts.’” Maxwell Br. at 2. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…Document
315-2, 08/09/2019,
977-1 Filed2628211,
08/09/19Page16
Page of
1625
…
giuffre-maxwell
gov.uscourts.nysd.447706.995.0
11 pg
…such
3
Case 1:15-cv-07433-LAP Document 995 Filed 10/02/19 Page 5 of 11
evidentiary and discovery matters can cause substantial harm. Such materials are
therefore of value to those monitoring the federal courts. Thus…
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…s victims.
Separately, the Court shall provide to the USVI a copy of a
prior order, docketed under seal, explaining why the Court-ordered
disclosure to Mr. Dershowitz of materials mentioning him (See
Order, dated Sept. 9, 2020 [dkt. no…
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