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.447706.1307.4
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
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.447706.1296.2
17 pg
…this Court
Ordered Defendant to sit for a second deposition because her refusal to answer questions posed
in her first Deposition (June 20, 2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,
during her second deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…this Court
Ordered Defendant to sit for a second deposition because her refusal to answer questions posed
in her first Deposition (June 20, 2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,
during her second deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…this Court
Ordered Defendant to sit for a second deposition because her refusal to answer questions posed
-
in her first Deposition (June 20, 2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,
during her second deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.1
17 pg
…this Court
Ordered Defendant to sit for a second deposition because her refusal to answer questions posed
in her first Deposition (June 20, 2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,
during her second deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1021.0
18 pg
…the first five or something like that.
11 MS. WALZ: To the extent there is a third-party name
12 or something like that that counsel feels must be redacted, can
13 it be just redacted?
14 THE COURT: Of…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.5
465 pg
…report, Ms. Maxwell, the redacted
4 information is redacted because it reveals
5 the name of a minor, someone who is under the
6 age of 18.
7 On page 28, in the third paragraph,
8 about halfway down, it…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.1
465 pg
…report, Ms. Maxwell, the redacted
4 information is redacted because it reveals
5 the name of a minor, someone who is under the
6 age of 18.
7 On page 28, in the third paragraph,
8 about halfway down, it…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.13_5
465 pg
…report, Ms. Maxwell, the redacted
4 information is redacted because it reveals
5 the name of a minor, someone who is under the
6 age of 18.
7 On page 28, in the third paragraph,
8 about halfway down, it…
giuffre-maxwell
gov.uscourts.nysd.447706.363.0
18 pg
…the Court grants my application, I would also request that the Court
unseal the Requested Documents along with all of the references to them in my motion papers
that are being redacted from the public docket.
4.
2
5. …
giuffre-maxwell
gov.uscourts.nysd.447706.1308.1
465 pg
…report, Ms. Maxwell, the redacted
4 information is redacted because it reveals
5 the name of a minor, someone who is under the
6 age of 18.
7 On page 28, in the third paragraph,
8 about halfway down, it…
giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…s objection claims that unsealing would be detrimental to
their wellbeing. Plaintiff does not object to keeping Doe 28’s name sealed in excerpts that discuss
Doe 28 being sexually abused. 4 Such excerpts should redact Doe 28’s name…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.4
106 pg
…Maxwell, the redacted
4 MR. PAGLIUCA: I'm going to object 4 information is redacted because it reveals
5 to you interrupting the witness who was 5 the name of a minor, someone who is under the
6 answering your…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…case. That's their listing. All it
17 is is the names of people.
18 I have absolutely no idea or ability to understand why
19 someone's name could be considered to be confidential. It is
20 their name…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.19
106 pg
…Maxwell, the redacted
4 MR. PAGLIUCA: I'm going to object 4 information is redacted because it reveals
5 to you interrupting the witness who was 5 the name of a minor, someone who is under the
6 answering your…
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