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.447706.1196.0
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.447706.1284.0
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.447706.992.0
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.447706.996.0
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…
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.447706.1218.14
32 pg
…was advising Ms.
Giuffre about how to maximize her payments for selling her story, first
raised the idea of mentioning Professor Dershowitz in connection with the
alleged abuse, despite the fact that there was “no proof” that he was
involved…
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.447706.1211.0_1
5 pg
…It is, nevertheless, important to the public’ interest in
monitoring federal court’s exercise of their Article II powers
that the public reviews the documents.”) 6-7; (“Public access to
certain parts of this transcript is outweighed by Ms. Maxwell…
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.447706.1220.0
17 pg
… It is,
2 nevertheless, important to the public's interest in monitoring
3 federal courts' exercise of their Article 3 powers. The Court
4 keeps this somewhat less substantial public presumption in mind
5 in determining whether it is outweighed…
giuffre-maxwell
gov.uscourts.nysd.447706.1242.0
9 pg
…4 Even in one of the cases that Does 55 and 56 cite, the Court permitted
redactions of only the names and personally identifiable information of minors, not wholesale
sealing of judicial documents mentioning minors. See United States v. Johnson…
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.447706.1067.0
10 pg
…the Court said that it was “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.” Intervenors ask that the Court follow the…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.50
15 pg
…Ms. Giuffre
attempts no rejoinder to the reasoning of Mokhiber and its progeny: that modern discovery
motions are core judicial processes that “may prove decisive to the outcome of particular
disputes” and therefore must be open to public monitoring. Mokhiber…
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