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.447706.1335.5
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.447706.1137.15_2
41 pg
…prevail on the motion to add her to
the current litigation, the only consequence would be that Ms. [name redacted]
would then file a separate CVRA lawsuit, something she is entitled to do because
the CVRA contains no time limit. …
giuffre-maxwell
gov.uscourts.nysd.447706.1080.0
2 pg
…discern who the nonparty is, despite the name being redacted.
Case 1:15-cv-07433-LAP Document 1080 Filed 07/29/20 Page 2 of 2
intends to shield large portions of her own deposition testimony from publication. Further…
giuffre-maxwell
gov.uscourts.nysd.447706.1128.0_4
1 pg
…Documents Ordered Unsealed by Order of July 23, 2020.”
ECF No. 1077.
Sincerely,
/s/ Sigrid McCawley
Sigrid S. McCawley, Esq.
cc: Counsel of Record (via ECF)
1
Doe 1’s name is …
giuffre-maxwell
gov.uscourts.nysd.447706.1226.0
4 pg
…2020), https://slate.com/news-and-
politics/2020/10/ghislaine-maxwell-deposition-redactions-epstein-how-to-crack.html. In other
contexts, the subject matter of the publicly disclosed excerpts allows the identification of the
redacted name. See, e.g., Jim…
giuffre-maxwell
gov.uscourts.nysd.447706.1130.0_3
1 pg
…Documents Ordered Unsealed by Order of July 23, 2020.”
ECF No. 1077.
Sincerely,
/s/ Sigrid McCawley
Sigrid S. McCawley, Esq.
cc: Counsel of Record (via ECF)
1
Doe 1’s name is …
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…the
address book contained the circled names of many celebrities and other individuals, including
, among others.8 Even the late
name and redacted phone number was in the “black book.” And yet, Mr. Cassell seems to have
falsely assumed that…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
…including
Donald Trump, Flavio Briatore, and Courtney Love, among others.8 Even the late Elie Wiesel’s
name and redacted phone number was in the “black book.” And yet, Mr. Cassell seems to have
falsely assumed that, among those individuals…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…unpublished manuscript alleged she was lent to for sexual purposes. His name has
been redacted from the version of the manuscript unsealed as part of the summary judgment record
in Maxwell, and he is one of the very few individuals…
giuffre-maxwell
gov.uscourts.nysd.447706.1154.0_5
3 pg
…the proceedings at all. Doe
#84’s name was mentioned in some of the sealed summary judgment pleadings, and the
Second Circuit sua sponte redacted the name and the deposition testimony based on that Non-
Party’s privacy interests. See…
giuffre-maxwell
gov.uscourts.nysd.447706.710.0
1 pg
…s Reply/Combined
Opposition; therefore, the redaction of non-party’s name on page 1 and signature block
on page 23 do not affect the original un-redacted reply or supporting declaration
submitted to the Court. Accordingly, re-filed DE…
giuffre-maxwell
gov.uscourts.nysd.447706.363.5
6 pg
…SUBPOENA TO ATTEND ??ATTEND AND PRODUCE
To: __Jane Doe #3_(address redacted for purpose of court filing)
You are ordered to attend and give testimony at the District Court of Fremont County, located at: 136
Justice Center Road, Canon City…
giuffre-maxwell
gov.uscourts.nysd.447706.1084.0
1 pg
…While I cannot determine the information in the redacted form, it may be
that those pages are pages that the Second Circuit has already released and thus the name remained
unredacted in the form set forth by the Second Circuit…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
… Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S NON-REDACTED MOTION TO EXCEED PRESUMPTIVE TEN
DEPOSITION LIMIT IN FEDERAL RULE CIVIL PROCEDURE 30(A)(2)(a)(ii)
Sigrid McCawley (Pro H…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
… Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S NON-REDACTED MOTION TO EXCEED PRESUMPTIVE TEN
DEPOSITION LIMIT IN FEDERAL RULE CIVIL PROCEDURE 30(A)(2)(a)(ii)
Sigrid McCawley (Pro H…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
… Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S NON-REDACTED MOTION TO EXCEED PRESUMPTIVE TEN
DEPOSITION LIMIT IN FEDERAL RULE CIVIL PROCEDURE 30(A)(2)(a)(ii)
Sigrid McCawley (Pro H…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.3
28 pg
… Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S NON-REDACTED MOTION TO EXCEED PRESUMPTIVE TEN
DEPOSITION LIMIT IN FEDERAL RULE CIVIL PROCEDURE 30(A)(2)(a)(ii)
Sigrid McCawley (Pro H…
giuffre-maxwell
1320-10
28 pg
… Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S NON-REDACTED MOTION TO EXCEED PRESUMPTIVE TEN
DEPOSITION LIMIT IN FEDERAL RULE CIVIL PROCEDURE 30(A)(2)(a)(ii)
Sigrid McCawley (Pro H…
giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…it
redacted a non-party’s name in one location but not another; so the media immediately
gained access to that name. As another example, it redacted Ms. Maxwell’s email
address (which linked to her own domain name) in…
Comments