…and was questioned extensively about, among other things: her relationship with Jeffrey Epstein, her knowledge of “sexual trafficking”, sex with minors, non-consensual sex, sex involving the Plaintiff and others, sex involving Plaintiff and Mr. Epstein, sex involving the Plaintiff…
…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…
…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…
…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…
…seal. Ms. Maxwell has previously detailed the example of Doe # 84, an alleged victim of Epstein’s when she was a minor. She testified at a deposition, represented by counsel, under the express promise of confidentiality under the Protective Order…
…he might consider benign and insignificant. However, Doe #100 likely has significant privacy and other interests in the unsealing of materials in which a person alleges he sexually abused a minor. In the second disclosure, he has a weighty “countervailing…