giuffre-maxwell
gov.uscourts.nysd.447706.1253.0
12 pg
…concerning the first set of Non-Party Objectors, the Court ordered that certain documents would
remain under seal where (i) a Non-Party Objector’s name was only mentioned in “a case of
mistaken identity”; (ii) Non-Party Does were…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…the street for “months” without word from
her family, and ultimately was rescued by the FBI in a SWAT raid from the
clutches of a sexual predator named Ron Eppinger, the police documented a call
from Plaintiff’s mom that…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…21 On Friday of this past week, on the 17th, they issued
22 a new -- defendants issued a new Rule 26 disclosure with 42 new
23 names on it, those of which were on our disclosures, without
24 marking it…
giuffre-maxwell
gov.uscourts.nysd.447706.1087.0
4 pg
…Giuffre’s proposed redactions--which include
minimal redactions of personally identifiable information, the
names of nonparties, and descriptions of nonparty conduct that
1
Case 1:15-cv-07433-LAP Document 1087 Filed 07/30/20 Page 2 of 4…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…non-
parties is no longer appropriate. Plaintiff respectfully requests that the Parties be permitted to
review and publish the sealed materials subject to redactions to protect the names and personally
identifiable information of victims only, which would greatly expedite the…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…as to all other judicial records, the Court should
balance the competing interests of public access and non-party privacy and reputational interests
by redacting the names and other identifying information of the non-parties. We further propose
for the…
giuffre-maxwell
gov.uscourts.nysd.447706.1247.1
4 pg
…of unsealing.
172 J. Doe 171, J. Doe 28 Unseal, but redact J. Doe 28’s name on page 13. Note: this document was partially
unsealed in prior round of unsealing.
173-5 J. Doe 144, J. Doe 183, J…
giuffre-maxwell
gov.uscourts.nysd.447706.1253.1
4 pg
…of unsealing.
172 J. Doe 171, J. Doe 28 Unseal, but redact J. Doe 28’s name on page 13. Note: this document was partially
unsealed in prior round of unsealing.
173-5 J. Doe 144, J. Doe 183, J…
giuffre-maxwell
gov.uscourts.nysd.447706.1313.0
1 pg
…s safety in
her current country, the Parties and the Miami Herald consent to redacting Doe 107’s name and
any personally identifying information in the docket entries that the Court previously ordered
unsealed. Giuffre’s and the Miami Herald…
giuffre-maxwell
gov.uscourts.nysd.447706.710.0
1 pg
…March 9, 2017 hearing, I submit this letter motion
requesting an endorsed order for relief granted by the Court (ore tenus application to
redact the non-party’s name from the record). 3/9/17 Hr’g Tr. at page…
giuffre-maxwell
gov.uscourts.nysd.447706.1080.0
2 pg
…that “personal identifying information as to any person mentioned in the
documents and the names of nonparties other than Does 1 and 2 and other portions related to such
nonparties’ specific conduct will be redacted from the materials being unsealed…
giuffre-maxwell
gov.uscourts.nysd.447706.1084.0
1 pg
…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. Alternatively there could have been…
giuffre-maxwell
gov.uscourts.nysd.447706.1154.0_5
3 pg
…that the Court will consider in this current round of unsealing not only whether to
release Doe 1 and 2’s names and identifying information but also the same information for
any Non-Party “whose deadlines to object have passed…
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.447706.1021.0
18 pg
… For example, if there are a reporter's
22 name mentioned in the document that wouldn't necessarily be
23 deemed a non-party that the Court would think would need to get
24 notice, we can separate those out…
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.447706.949.0
31 pg
…13 MR. BOHRER: Thank you, your Honor.
14 Your Honor, my name is Sandy Bohrer with the law firm
15 of Holland & Knight. We represent the Miami Herald. We're
16 seeking to intervene. We're the third party that…
giuffre-maxwell
gov.uscourts.nysd.447706.1083.0
3 pg
…pleadings to be unsealed three categories: 1) “personal identifying information as to any
person mentioned in the documents,” 2) “the names of nonparties other than Does 1 and 2,”
and 3) “other portions related to such nonparties’ specific conduct.” The…
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.447706.1026.2
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
…
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