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.447706.1219.28
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.447706.1328.33
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.447706.1219.13
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.447706.1196.0
32 pg
…nevertheless, important to the public's interest in
17 monitoring federal courts' exercise of their Article III powers
18 that the public review the documents.
19 With this presumption of public access in mind, the
20 Court turns to the…
giuffre-maxwell
gov.uscourts.nysd.447706.1305.0
4 pg
…s identity, failing to “include a ‘particularized’ or ‘individualized’ review” of materials to balance
the public’s interest in monitoring federal courts’ exercise of their powers against “countervailing
private interests,” and “failing to consider international comity.” Doe 171 Br. at…
giuffre-maxwell
gov.uscourts.nysd.447706.1124.0_3
2 pg
…nor Doe 2 requested Excerpts under the Protocol, the Original Parties submitted their own briefs,
and the Court ruled that the first five motions, including portions of those documents mentioning
Doe 1 or Doe 2, should be unsealed. ECF No…
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.447706.1284.0
17 pg
…for a
15 dispositive motion. It's nevertheless important to the
16 public's interest in monitoring federal courts' exercise of
17 their Article III powers.
18 With this presumption of public access in mind, the
19 Court turns to…
giuffre-maxwell
gov.uscourts.nysd.447706.1283.0
17 pg
…for a
15 dispositive motion. It's nevertheless important to the
16 public's interest in monitoring federal courts' exercise of
17 their Article III powers.
18 With this presumption of public access in mind, the
19 Court turns to…
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.447706.1123.0
2 pg
…concerns may be help explain
the Doe 1 email. These two Does cannot properly formulate their objections or non-
objections until they have had a chance to review the excerpts mentioning them. For example,
they don’t really know how…
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.447706.1143.0_1
2 pg
…order explaining
that the Court is “amenable to unsealing portions of documents mentioning non-parties rather than
waiting to unseal the entirety of a given document until all non-parties have provided input” and
that [t]his will hopefully allow…
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.447706.1247.0
25 pg
…wrongdoing. In any
event, the excerpts mentioning Doe 107 do not accuse them of any wrongdoing at all. The Rule
26 disclosures only state that Doe 107 may have knowledge of the sex-trafficking scheme at issue
in this case…
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