…2021 (“January 6 Order”), see DE 233. 1 This appears to be yet another attempt by the Dershowitz parties to evade this Court’s carefully constructed privacy protections, by requesting (i) access to non-party information from Giuffre v. Maxwell…
…and 1320-40 in the above-captioned case because they contain personally identifiable information, the disclosure of which could threaten the safety and privacy of named individuals. Counsel shall redact the personally identifiable information and re-file the stricken documents…
…into the Court’s balancing of considerations – as it is ultimately the responsibility of this Court, and not the parties or even non-parties, to protect non-party privacy interests. I. Mr. Dershowitz’s Proposed Disclosure of Confidential Maxwell Materials …
…That protocol, which was first put in place more than two years ago, balances the presumption of public access to judicial documents against the privacy, reputational, and other countervailing interests that support the continued sealing of certain of the previously…
…20 Page 3 of 22 her counsel agreed, would be honored subject to the few very limited situations in which the public right to access the court files overcomes the privacy interests at stake. ARGUMENT I. Weight of Presumption Each…
…she does not wish to further address those objections. See Dkt. 1230 at 2. Each of the listed Does has counsel who have ably asserted their own respective privacy rights. Ms. Maxwell therefore leaves it to this Court to conduct…
… Ms. Maxwell objects to the Requests to the extent they seek information that is confidential and implicates Ms. Maxwell’s privacy interests. 9. Ms. Maxwell incorporates by reference every general objection set forth above into each specific response set forth…
…Court failed to conduct the requisite particularized review when ordering the sealing of the materials at issue. At the same time, we recognize the potential damage to privacy and reputation that may accompany public disclosure of hard‐fought, sensitive litigation…
…in the conferral and the conference. For the reasons we provided to the Second Circuit, we believe her participation and the participation of other third parties whose privacy interests are implicated are appropriate. Ms. Campbell expressed interest in participating in…
…2”).1 3. Annoyance, embarrassment, oppression, undue burden (“Privacy Interests”) (“CI- 3”). 4. Preserving the fundamental rights of suspects or others under criminal investigation (“CI-4”). 5. Improper submission of documents thereby weaponizing judicial documents (“CI…
…will (1) undermine the careful unsealing process agreed to by the parties in Maxwell, and (2) infringe on the privacy or other countervailing interests against disclosure of the Does without their having notice and an opportunity to be heard. Accordingly…
…Second, the proposed disclosure could “infringe on the privacy or other countervailing interests against disclosure of the Does [who are providing input in Maxwell] without their having notice and an opportunity to be heard.” (Id.) In light of those concerns…
…opinion, the Second Circuit suggested in dicta that “[t]he District Court may also order the parties to identify and notify additional parties whose privacy interests would likely be 1 Based on lessons learned from past rounds of unsealing, the…
…2016 letter from Kim E. Campbell, United States Secret service Special Agent In Charge, Freedom of Information Act and Privacy Act Officer, the "USSS has conducted a reasonable search for responsive records. It appears, from a review of USSS main…
…making statements to law enforcement (including making statements by and through her attorneys), Ms. Giuffre had an expectation of privacy in her communications with law enforcement. See Sanchez, 201 A.D.2d at 326 (statements with law enforcement are privileged).…
… Ms. Maxwell objects to the Requests to the extent they seek information that is confidential and implicates Ms. Maxwell’s privacy interests. 9. Ms. Maxwell incorporates by reference every general objection set forth above into each specific response set forth…
…m n o p q r s t u v w x y z more Browse members by country © 2016 User Agreement Privacy Policy Community Guidelines Cookie Policy Copyright Policy Unsubscribe https://www.linkedin.com/in/ross-gow-41395124…
…Dershowitz covered three general tracks. First, the comments noted the gravity of the privacy and reputational interests that would be implicated by any disclosure to Mr. Dershowitz. For example, one Doe noted the potential impact of any disclosure on the…
…Court failed to conduct the requisite particularized review when ordering the sealing of the materials at issue. At the same time, we recognize the potential damage to privacy and reputation that may accompany public disclosure of hard‐fought, sensitive litigation…
…Ms. Maxwell and the non-parties such as Mr. Doe have objected to unsealing and are seeking to protect their privacy and other interests. We respectfully submit that these interests can be protected by entry of an order granting Mr…
Comments