…Reality: Courts routinely seal records concerning underage victims – well beyond replacing their names with initials – and victims do not forego their rights to privacy merely because they have played a role in a civil or criminal case against perpetrators. As…
…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…
…have failed to meet the burden to demonstrate that any of these documents should remain sealed. Generalized Privacy Concerns Do Not Warrant Sealing This Court has already held that generalized concerns about embarrassment are insufficient to support sealing judicial documents…
…party witnesses. Release of such confidential information outside of the litigation could expose the parties to ‘annoyance, embarrassment, [and] oppression and result in significant injury to one or more of the parties’ business or privacy interests.” - Defendant, Ghislaine Maxwell, March…
…Brown v. Maxwell, 929 F.3d 41, 47 n.13 (2d Cir. 2019) (noting that it is the “privacy interest of those who resist disclose” that serve as a countervailing interest) (quoting S.E.C. v. TheStreet.Com, 273 F…
… Ms. Maxwell objects to the Interrogatories 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…
…On March 18, 2016, this Court entered a Protective Order (DE 62) for the privacy of the parties and deponents. Non-Party Jane Doe 43 was a fact witness and deponent in the Giuffre v. Maxwell case. She provided both…
… 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…
…the identity of Ms. Giuffre's minor children, and to protect Ms. Giuffre's privacy interests which are naturally implicated in the potential release of domestic violence records. Colorado statutes recognize and protect the privacy of domestic violence victims, see…
…party witnesses. Release of such confidential information outside of the litigation could expose the parties to ‘annoyance, embarrassment, [and] oppression and result in significant injury to one or more of the parties’ business or privacy interests.” - Defendant, Ghislaine Maxwell, March…
…other. As discussed in more detail below, the former group can maintain privacy by narrowly redacting information that would identify those who have not previously been publicly identified 1 As with prior filings, counsel for Intervenors have seen only Ms…
…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…
…identity of these non-party potential witnesses, Ms. Giuffre has fittingly marked her Rule 26 Disclosures as confidential. The designation is made in good faith to protect these individuals and their privacy, who are victims of sexual abuse (or, alternatively…
… 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…
…See ECF No. 892. The Newspapers are aware of the general privacy interests at stake in this case, and that the parties and witnesses relied on the existence of the protective orders in place when providing testimony and evidence in…
…or unduly burdensome are not acceptable, and will be overruled.”). Maxwell’s general objection to producing material that implicates “privacy interests” is equally misplaced. Maxwell does not have a “privacy interest” in the illegal sexual abuse and trafficking of Ms…
…embarrassment, loss of self-esteem, loss of standing in the community, loss of dignity and invasion of privacy in her public and private life not less than $30,000,000.00. a. Computation Analysis i. Under New York law, defamation…
…holding that trial court departed from the essential requirements of law by granting deposition of party’s gynecologist which was only meant to invade privacy and intimidate and harass the party). Defendant also has a number of requests (Request nos…
…3, Ms. Giuffre struck the word “implicates” and replaced it with “is covered by” because many things can “implicate” but only those things that are actually “covered by a common law and statutory privacy protection” should be deemed “confidential”. Ms…
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