giuffre-maxwell
gov.uscourts.nysd.447706.1004.0
1 pg
…07433-LAP
Dear Judge Preska,
The parties have conferred and write today to seek clarification regarding the Court’s
request for a list of names and contact information that is referenced in paragraph 2 of the Court’s
October 28…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.0
18 pg
…a well-known
Prime Minister, and other world leaders.” (Id. at 3-6). She names several individuals, and she
offers details about the type of sex acts performed and where they took place. (See id. at 5).2
At this…
giuffre-maxwell
gov.uscourts.nysd.447706.185.4
10 pg
…a well-known
Prime Minister, and other world leaders.” (Id. at 3-6). She names several individuals, and she
offers details about the type of sex acts performed and where they took place. (See id. at 5).2
At this…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.1
13 pg
…abuse;
g. Dershowitz showed up on flight logs for Epstein’s private jet, including a
flight with an (apparently young) woman named “Tatiana” who did not appear
to serve any business purpose for Epstein;
h. When asked about Dershowitz, Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.363.4
11 pg
…a well-known
Prime Minister, and other world leaders.” (Id. at 3-6). She names several individuals, and she
offers details about the type of sex acts performed and where they took place. (See id. at 5).2
At this…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.45
13 pg
…sexual abuse;
g. Dershowitz showed up on flight logs for Epstein’s private jet, including a
flight with an (apparently young) woman named who did not appear
to serve any business purpose for Epstein;
h. When asked about Dershowitz, Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.5
11 pg
…a well-known
Prime Minister, and other world leaders.” (Id. at 3-6). She names several individuals, and she
offers details about the type of sex acts performed and where they took place. (See id. at 5).2
At this…
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.447706.1050.0
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.447706.1034.0
16 pg
…fulsome list
provided by Defendants, which strikes the names of reporters,
1
Case 1:15-cv-07433-LAP Document 1034 Filed 03/19/20 Page 2 of 16
Plaintiff’s medical providers, and law enforcement personnel
but retains all…
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.447706.1026.1
4 pg
…Court (Dkt. 1007-1).
Case 1:15-cv-07433-LAP Document 1026-1 Filed 01/30/20 Page 2 of 4
The Non-Parties List will:
Identify each Non-Party by his or her name, which correlates to…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.2
4 pg
…Page 2 of 4
is described in the Sealed Materials; and (d) persons who are alleged to have been victimized.
The Non-Parties List will:
Identify each Non-Party by his or her name, which correlates to a unique
…
giuffre-maxwell
gov.uscourts.nysd.447706.1226.0
4 pg
…to be masked by
the redactions. In certain instances, the released materials include a deposition index which
allows a reader to readily compare the redaction with the corresponding page index and identify
the non-party’s name. See, e.g.…
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…
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.447706.1052.0
4 pg
…2 of 4
the First Five Motions (and their accompanying papers) that those documents may be unsealed,
and that once all Non-Parties whose name appears in the First Five Motions are notified and have
had an opportunity to object…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…(Jane Doe 3,
Virginia Giuffre, subsequently decided to reveal her name). The joinder motion argued that Jane
Does 3 and 4 should be allowed to join the two existing plaintiffs in the action because they had
suffered the same violations…
giuffre-maxwell
gov.uscourts.nysd.447706.1254.0
18 pg
…Maxwell's criminal trial.
6 As to the nonparty Does, as to the names and
7 identifying information of the objecting nonparty Does, much of
8 the purportedly sensitive information has already become public
9 in the course of Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.6
10 pg
…federal, or common law.
Notwithslanding this waiver, u to those individuals ·whose names
appear on the list provided by the United States, Epstein's signature on
this agreement, his waivers and failum to contest liability and such
~ c s…
Comments