giuffre-maxwell
gov.uscourts.nysd.447706.1125.0_2
5 pg
…stating that Doe 1 and Doe 2 did
not generally object to unsealing documents, (2) objecting to the
unsealing of their names out of respect for their privacy, and (3)
requesting excerpts of sealed materials that mention them for their…
giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1192.0_3
3 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.928.0
11 pg
…this Court entered a Protective Order (DE 62) for the privacy of the
parties and deponents.
1
Case 1:15-cv-07433-LAP Document 928 Filed 10/19/17 Page 2 of 11
2
Case 1:15-cv-07433…
giuffre-maxwell
gov.uscourts.nysd.447706.1324.0
1 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.977.2
1 pg
…task. As the Court’s opinion recognizes in connection with the remaining
sealed materials, the district court is better positioned to communicate with the
parties and any nonparties whose privacy interests might be affected by
unsealing. On that score, it…
giuffre-maxwell
gov.uscourts.nysd.447706.968.1
1 pg
…task. As the Court’s opinion recognizes in connection with the remaining
sealed materials, the district court is better positioned to communicate with the
parties and any nonparties whose privacy interests might be affected by
unsealing. On that score, it…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…Non-Parties List: Plaintiff Virginia Giuffre and Defendant Ghislaine Maxwell
(collectively, the “Original Parties”) each have submitted under seal a list of non-parties whose
privacy, reputational or other interests may be implicated by the unsealing of the Sealed Materials…
giuffre-maxwell
gov.uscourts.nysd.447706.1105.0
8 pg
…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
…
giuffre-maxwell
gov.uscourts.nysd.447706.1264.0
1 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1238.0
1 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1240.0
5 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1329.0
3 pg
…no. 1321 at 2.)
Second, even so, the privacy interests at stake outweigh any
presumption of public access to the Document. The public does not
have an absolute right to access and inspect court documents;
rather, courts may exercise their…
giuffre-maxwell
gov.uscourts.nysd.447706.1124.0_3
2 pg
…(2) objected to the unsealing of their names out of respect for their “privacy,” and (3)
requested excerpts for their “review.” They also provided Doe 1’s current address—the same
Case 1:15-cv-07433-LAP…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.17
25 pg
… 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…
giuffre-maxwell
gov.uscourts.nysd.447706.1278.0
4 pg
…were retained
to represent her in this matter. The privacy interests at stake in this litigation are the
subject of considerable complexity that Doe 171’s undersigned counsel are still
attempting to digest. Although Doe 171’s undersigned counsel still…
giuffre-maxwell
gov.uscourts.nysd.447706.1157.0_1
5 pg
…Protocol, is that the
“solicitation and receipt of objections from Non-Parties who
wish to participate is intended merely to aid the Court in
balancing privacy and other interests against the public’s right
of access.” (Protocol at 5.) Accordingly…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.4_1
4 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1285.0
6 pg
…1:15-cv-07433-LAP Document 1285 Filed 12/05/22 Page 2 of 6
information necessary to evaluate her privacy interests at stake.) See also Appendix
(Summary Chart).1
While Doe 171 strenuously maintains her right to remain anonymous…
giuffre-maxwell
gov.uscourts.nysd.447706.1042.0
2 pg
…filing” is misleading. After the
objections are considered, it is likely that Non-Parties will be identified because the public interest
in disclosure outweighs any asserted privacy interest or other counterailing interest.
And third, in response to J. Doe’s…
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