giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…The Intervenors’ requests to unseal should be denied.
A. Intervenors’ First Proposition of Law: For minor victims of sexual abuse, “redactions
should be applied sparingly to shield only information that would identify those who
have not already been publicly identified…
giuffre-maxwell
gov.uscourts.nysd.447706.968.1
1 pg
…The task of identifying
and making specific redactions in such a substantial volume is perilous; the
consequences of even a seemingly minor error may be grave and are irrevocable.
Moreover, although I share the majority’s concern about avoiding delay…
giuffre-maxwell
gov.uscourts.nysd.447706.1070.0
1 pg
…without redaction after ninety (90) calendar days.
This process may only be used to redact the following personal data identifiers: Social Security
numbers; dates of birth; minors’ names; and financial account numbers. See Federal Rule of Civil Procedure
5.2…
giuffre-maxwell
gov.uscourts.nysd.447706.1197.0_1
1 pg
…without redaction after ninety (90) calendar days.
This process may only be used to redact the following personal data identifiers: Social Security
numbers; dates of birth; minors’ names; and financial account numbers. See Federal Rule of Civil Procedure
5.2…
giuffre-maxwell
gov.uscourts.nysd.447706.1022.0
1 pg
…without redaction after ninety (90) calendar days.
This process may only be used to redact the following personal data identifiers: Social Security
numbers; dates of birth; minors’ names; and financial account numbers. See Federal Rule of Civil Procedure
5.2…
giuffre-maxwell
gov.uscourts.nysd.447706.32.0
1 pg
…without redaction after
ninety (90) calendar days.
This process may only be used to redact the following personal data identifiers: Social-
Security numbers; dates of birth; minors’ names; and financial account numbers. See Federal
Rule of Civil Procedure 5.2…
giuffre-maxwell
gov.uscourts.nysd.447706.1329.0
3 pg
…outcome is particularly likely in
the wake of the recent media frenzy about some supposed “Epstein
List” and the mass speculation about the identities of those on
it. The Document includes minor victims, health care providers,
members of law enforcement…
giuffre-maxwell
gov.uscourts.nysd.447706.977.2
1 pg
…The task of identifying
and making specific redactions in such a substantial volume is perilous; the
consequences of even a seemingly minor error may be grave and are irrevocable.
Moreover, although I share the majority’s concern about avoiding delay…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.0
3 pg
…93, and 151.
Finally, the Parties have largely agreed to revisions to the Order and Protocol for Unsealing
Decided Motions, with one minor disagreement. Attached as Exhibit A hereto is Plaintiff’s
proposed version, in redline to the current version…
giuffre-maxwell
gov.uscourts.nysd.447706.1253.0
12 pg
…was only mentioned in “a case of
mistaken identity”; (ii) Non-Party Does were minors at the time who “played no part in the
allegations that form the basis of this action”; or (iii) Non-Party Does have “not been…
giuffre-maxwell
gov.uscourts.nysd.447706.1255.0
1 pg
…without redaction after ninety (90) calendar days.
This process may only be used to redact the following personal data identifiers: Social Security
numbers; dates of birth; minors’ names; and financial account numbers. See Federal Rule of Civil Procedure
5.2…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…and social security numbers;” (2) “the names
of alleged minor victims of sexual abuse;” and (3) “deposition responses concerning intimate
matters where the questions were likely only permitted—and the responses only compelled—
because of a strong expectation of continued…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…Plaintiff and her 17-year old boyfriend verified they had had sexual
intercourse in the days before the report, and the boyfriend was charged with
having sexual contact with a minor. Those were not the false allegations of
sexual contact…
giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…Preska
November 16, 2019
Page 3
numbers,” and “the names of alleged minor victims of sexual abuse from deposition
testimony and police reports, as well as deposition responses concerning intimate
matters where the questions were likely only permitted—and the…
giuffre-maxwell
gov.uscourts.nysd.447706.1196.0
32 pg
…for certain police
4 reports, the privacy interests of certain persons warrant
5 continued sealing where they were minor victims. Because these
6 police reports were obtained through a public records request,
7 they should be unsealed and docketed in…
giuffre-maxwell
gov.uscourts.nysd.447706.1154.0_5
3 pg
…under the express promise of confidentiality under the Protective
Order. This individual accused Mr. Epstein of wrongdoing perpetrated when the individual
was minor. During the deposition, the Non-Party testified that they had undergone extensive
therapy to overcome the trauma…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…Giuffre in the instant
motion. Instead, Defendant says that the police report documenting Ms. Giuffre’s rape while a
minor has her name redacted. Of course, such a redaction does Ms. Giuffre little good when
Defendant and her cohorts distribute…
giuffre-maxwell
gov.uscourts.nysd.447706.1242.0
9 pg
…1242 Filed 02/16/22 Page 5 of 9
Case 1:15-cv-07433-LAP Document 1242 Filed 02/16/22 Page 6 of 9
alleged victims of sexual abuse, not merely because they were minors. 3 Hilbert S…
giuffre-maxwell
gov.uscourts.nysd.447706.1167.2
27 pg
…2
CI-3 Unseal but redact (1) information
272-7 7.12.16 Keep sealed CI-4 about Plaintiff when a minor and
CI-5 (2) medical information.
272-8 7.12.16 No objection to unseali…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…reporting while, on the other, her own privacy should be protected.
Plaintiff also wants to keep confidential numerous records because they concern
“information about events when plaintiff was a minor.” See DE 1156-1 at Lines re. 381-1, 381…
Comments