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.447706.1130.0_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.447706.1106.0_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…unpublished manuscript alleged she was lent to for sexual purposes.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.447706.710.0
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.447706.1084.0
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.447706.1050.0
12 pg
…please, when you
2 speak to say your name first so that the court reporter is able
3 to do a good transcript.
4 We have looked at your various letters regarding the
5 protocol, and with respect to paragraph…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.26
5 pg
…you see the redacted
15 portions where there is black so it blacks
16 out the name.
17 A. I see black redacted portions.
18 Q. That's a black redaction of the
19 name of the minor and there…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.13_1
3 pg
…your letter of June 8, 2016. The RFP requires defendant to “produce all
documents concerning Virginia Giuffre (a/k/a Virginia Roberts), whether or
not they reference her by name. This request includes, but is not limited to, all
communications…
giuffre-maxwell
gov.uscourts.nysd.447706.1083.0
3 pg
…For example, in , plaintiff proposes redacting
the name of alleged victims in some places (e.g., pages ) but not in others (e.g., page ).
Both of these two alleged victims are represented by counsel and sought confidentiality for
their depositions…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.5_1
3 pg
…your letter of June 8, 2016. The RFP requires defendant to “produce all
documents concerning Virginia Giuffre (a/k/a Virginia Roberts), whether or
not they reference her by name. This request includes, but is not limited to, all
communications…
giuffre-maxwell
gov.uscourts.nysd.447706.1028.0
5 pg
…2020
The Honorable Loretta A. Preska
United States District Court
Southern District of New York
500 Pearl Street
New York, NY 10007
Re: Defendant Maxwell’s Letter Brief re Materials That Should Remain Sealed or
Redacted
Giuffre v. Maxwell, No…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…who are alleged to have been victimized.
1
Case 1:15-cv-07433-LAP Document 1037-1 Filed 03/26/20 Page 2 of 14
The Non-Parties List will:
• Identify each Non-Party by his or her name…
giuffre-maxwell
gov.uscourts.nysd.447706.1034.0
16 pg
…2019).
4. Notice of Appellate Rights: The Protocol will include the
provision notifying non-parties of their appellate rights
with respect to any decision to unseal a document mentioning
their name. That provision will provide that “[a]n order
from…
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.447706.1250.0
7 pg
…See id. at *3 (“The respondents d[id] not contend that the [state-court documents] were
filed under seal or redacted in the state court to protect the identity of the victim of sexual
abuse.” (internal quotation marks omitted)), but…
giuffre-maxwell
gov.uscourts.nysd.447706.1025.0
17 pg
…contemplate that for each non-party submission the Court’s staff would substitute
in the redacted version the pseudonymous identifier for the non-party’s name, redact
as appropriate the submission, and file the redacted version in the ECF system…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.1
7 pg
…are alleged to have been victimized.
3
Case 1:15-cv-07433-LAP Document 1232-1 Filed 10/29/21 Page 3 of 7
The Non-Parties List will:
Identify each Non-Party by his or her name…
giuffre-maxwell
gov.uscourts.nysd.447706.201.0
5 pg
…c]ertain witnesses' . . . names
[were] redacted in accordance with the protective order”).
The Court’s inherent power to protect witnesses is crucial when applied to protect
witnesses who are victims of, or witnesses to, sexual abuse and sexual crimes. Indeed…
giuffre-maxwell
gov.uscourts.nysd.447706.1044.0
13 pg
…persons who are alleged to have been victimized.
The Non-Parties List will:
1
Case 1:15-cv-07433-LAP Document 1044 Filed 03/31/20 Page 2 of 13
• Identify each Non-Party by his or her name…
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