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.447706.1199.4_1
4 pg
…good faith basis for keeping the details of the
rape of a 14 year old girl, and the reactions of Ms. Giuffre' s minor children to domestic violence,
outside of the public realm. See May 18, 2016 letter from J…
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.447706.382.0
2 pg
…pending motion to intervene and to unseal documents.
2. In my previous declaration, I characterized the offenses to which Jeffrey Epstein
pleaded guilty as “involving sex with minors” (¶ 7) and “related to sex with minors” (¶ 10).
These statements were imprecise…
giuffre-maxwell
gov.uscourts.nysd.447706.40.0
8 pg
…is attached in both a redlined version and a clean version (See McCawley Decl. at Exhibit 5),
addresses the following important issues:
Opening Paragraph: Given the fact that this case involves sexual abuse
allegations of a minor child, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.18
5 pg
…age*
344) minor*
345) daily* w/10 mail*
346) daily* w/10 news*
347) lie*
348) obvious* w/10 lie*
349) sex w/3 toy*
350) nipple*
351) schoolgirl
352) school w/3 girl
353) us w/3 att*
354…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.1_1
13 pg
…nor disseminate them to third parties. They contain personal, sensitive, and embarrassing
information. Many of them also concern minors and a victim of sexual assault; therefore, they are
protected by various state statutes. Ms. Giuffre requests that this Court maintain…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.26
5 pg
… That's a black redaction of the
19 name of the minor and there is -- I will
20 represent for the record that's what it is.
21 You can contest that but I'm not asking about
22 the…
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.447706.1119.0_3
4 pg
…mandate, the Second Circuit specifically made these materials available on its own docket,
subject to what it held were appropriate redactions for personally identifying information, names
of alleged minor victims of sexual abuse, and deposition responses disclosing intimate matters.
Id…
giuffre-maxwell
gov.uscourts.nysd.447706.103.2
3 pg
…the Southern District of Florida (the “Office”), the Office was recused by the Department of
Justice from prospective responsibility for any criminal investigation or potential prosecution
relating to Jeffrey Epstein’s alleged sexual activities with minor females. As a result…
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.447706.541.0
10 pg
…1999. .................................... 56
2. The January 2015 statement accurately denied that Ms. Maxwell
“regularly participate[d] in Epstein’s sexual exploitation of minors” and
that “the Government knows” such fact. ..................…
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.447706.899.0
1 pg
…As the newspapers suggest, it is unlikely that the entirety of these documents
should properly be sealed, especially where none of the witnesses are minors. Moreover,
the Court seems to have misunderstood Intervenor’s motion to unseal. Intervenor did not…
Comments