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.447706.995.0
11 pg
…background of this case, to serve as a de facto Special Master over a process governing which
documents the public is allowed to access concerning this matter involving the serious issue of
abuse of minors.
1. Who Is John Doe…
giuffre-maxwell
gov.uscourts.nysd.447706.185.4
10 pg
…1).
Generally, they allege that the respondent Government violated their rights under the CVRA by
failing to consult with them before negotiating a non-prosecution agreement with Jeffrey Epstein,
who subjected them to various sexual crimes while they were minors. …
giuffre-maxwell
gov.uscourts.nysd.447706.542.5
11 pg
…1).
Generally, they allege that the respondent Government violated their rights under the CVRA by
failing to consult with them before negotiating a non -prosecution agreement with Jeffrey Epstein,
who subjected them to various sexual crimes while they were minors. …
giuffre-maxwell
gov.uscourts.nysd.447706.363.4
11 pg
…1).
Generally, they allege that the respondent Government violated their rights under the CVRA by
failing to consult with them before negotiating a non-prosecution agreement with Jeffrey Epstein,
who subjected them to various sexual crimes while they were minors. …
giuffre-maxwell
gov.uscourts.nysd.447706.1214.0
7 pg
…unsealed.
As set forth in Intervenors’ prior responses, any privacy rights Ms. Maxwell may have are
far outweighed by the public interest in allegations of sexual trafficking of minors, Ms. Maxwell’s
reliance on the protective order was not reasonable…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.5
11 pg
…1).
Generally, they allege that the respondent Government violated their rights under the CVRA by
failing to consult with them before negotiating a non-prosecution agreement with Jeffrey Epstein,
who subjected them to various sexual crimes while they were minors. …
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…UNSEALING OF SEALED DOCUMENTS
A Federal Court authorized this notice. This is not a solicitation from a lawyer.
This case involves allegations of sexual abuse and sexual trafficking of minors. Some
documents submitted to the Court were filed under seal…
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.447706.1254.0
18 pg
…12 Does 55 and 56. These Does were minors at the time of
13 the incidents at issue in this action and played no part in the
14 allegations that form the basis of this action. There is no
15…
giuffre-maxwell
gov.uscourts.nysd.447706.1034.0
16 pg
…UNSEALING OF SEALED DOCUMENTS
A Federal Court authorized this notice. This is not a solicitation from a lawyer.
This case involves allegations of sexual abuse and sexual trafficking of minors. Some documents
submitted to the Court were filed under seal…
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.447706.1167.2
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.447706.1074.0
18 pg
…1).
Generally, they allege that the respondent Government violated their rights under the CVRA by
failing to consult with them before negotiating a non-prosecution agreement with Jeffrey Epstein,
who subjected them to various sexual crimes while they were minors. …
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1067.0
10 pg
…Sexual content alone is insufficient to justify continued sealing of Ms. Maxwell’s
deposition transcript. This case concerns allegations of sexual assault and trafficking of
minors. There is no recognized privacy interest in allegations of sex trafficking. Any
privacy interest…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.1
16 pg
…information.
272-5 Already publicly filed (DE 45).
272-6 Already publicly filed (DE 31).
Unseal but redact (1) information about Plaintiff when a minor
272-7
and (2) medical information.
272-8 Keep sealed (medical records)
…
giuffre-maxwell
gov.uscourts.nysd.447706.1025.0
17 pg
…UNSEALING OF SEALED DOCUMENTS
A Federal Court authorized this notice. This is not a solicitation from a lawyer.
This case involves allegations of sexual abuse and sexual trafficking of minors. Some documents
submitted to the Court were filed under seal…
giuffre-maxwell
gov.uscourts.nysd.447706.946.0_1
14 pg
…ongoing coverage of
crimes committed by Jeffrey Epstein, the South Florida financier who pleaded guilty in 2008 to
solicitation of minors for prostitution and was suspected of involvement in a larger sex-trafficking
organization. Serious questions remain as to whether…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.0
16 pg
…UNSEALING OF SEALED DOCUMENTS
A Federal Court authorized this notice. This is not a solicitation from a lawyer.
This case involves allegations of sexual abuse and sexual trafficking of minors. Some
documents submitted to the Court were filed under seal…