giuffre-maxwell
gov.uscourts.nysd.447706.1287.0
2 pg
…7433 (LAP)
VIRGINIA L. GIUFFRE,
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
/
NOTICE OF REDACTION REQUEST – TRANSCRIPT
In accordance with this Court’s forms and procedures, undersigned counsel acknowledges
that redactions o…
giuffre-maxwell
gov.uscourts.nysd.447706.1070.0
1 pg
… minors’ names; and financial account numbers. See Federal Rule of Civil Procedure
5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information
may proceed by motion.
I (we) certify that the foregoing…
giuffre-maxwell
gov.uscourts.nysd.447706.1255.0
1 pg
… minors’ names; and financial account numbers. See Federal Rule of Civil Procedure
5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information
may proceed by motion.
I (we) certify that the foregoing…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.1
4 pg
…constitute a “motion” for purposes of this
Order and Protocol. The following procedure shall be used for each set of motions reviewed by
the Court:
a. The Court will notify the parties via minute order (“Notification”) of the set of…
giuffre-maxwell
gov.uscourts.nysd.447706.1197.0_1
1 pg
… minors’ names; and financial account numbers. See Federal Rule of Civil Procedure
5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information
may proceed by motion.
I (we) certify that the foregoing…
giuffre-maxwell
gov.uscourts.nysd.447706.1025.0
17 pg
…for various reasons, most of which will be apparent,
e.g., the protocol did not address various substantive and procedural issues, it did not
account for the Court’s rulings and comments at the January 16 status conference, and,
in…
giuffre-maxwell
gov.uscourts.nysd.447706.1339.0
3 pg
… Case 1:15-cv-07433-LAP Document 1339 Filed 01/12/24 Page 2 of 3
to other categories of sensitive information set out in the Court’s
individual practices and Federal Rule of Civil Procedure 5.2.
Second…
giuffre-maxwell
gov.uscourts.nysd.447706.1022.0
1 pg
… minors’ names; and financial account numbers. See Federal Rule of Civil Procedure
5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information
may proceed by motion.
I (we) certify that the foregoing…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.1
7 pg
…allow the Court more easily to manage and review any objections from Non-
Parties. The following procedure shall be used for each set of Sealed Items reviewed by the
Court:
a. The Court will notify the parties via minute order…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…1352 at 1, Plaintiff respectfully
submits that the notice and objection procedures that this Court previously implemented for non-
parties is no longer appropriate. Plaintiff respectfully requests that the Parties be permitted to
review and publish the sealed materials subject…
giuffre-maxwell
gov.uscourts.nysd.447706.1226.0
4 pg
…release of Sealed Materials; (b) establishing a fixed schedule and procedure for both parties
and non-parties to promptly state their respective positions on the release of Sealed Materials,
including the opportunity to participate in an evidentiary hearing; and (c…
giuffre-maxwell
gov.uscourts.nysd.447706.32.0
1 pg
… minors’ names; and financial account numbers. See Federal
Rule of Civil Procedure 5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to
request redaction of other information may proceed by motion.
/s MICHAEL MCDANIEL
…
giuffre-maxwell
gov.uscourts.nysd.447706.1231.0
3 pg
…the public docket and (2) ensure that Intervenors have an opportunity
to respond to the Does’ objections.
The court outlined the following procedure regarding placement of the Does’ submissions
on the public docket in the unsealing protocol dated August 27…
giuffre-maxwell
gov.uscourts.nysd.447706.1108.0
5 pg
…the Court more easily to manage and review any objections from Non-
Parties. The following procedure shall be used for each set of Sealed Items reviewed by the
Court:
a. The Court will notify the parties via minute order (“Notification”…
giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…15-cv-07433-LAP Document 1020 Filed 01/17/20 Page 5 of 7
Honorable Loretta A. Preska
November 16, 2019
Page 5
Federal Rule of Civil Procedure 26(c) protective order, the information must remain
sealed. See Martindell v…
giuffre-maxwell
gov.uscourts.nysd.447706.1196.0
32 pg
…that Ms. Maxwell recognizes that she has
3 the Federal Rules of Criminal Procedure and evidence at her
4 disposal when the appropriate time comes to fight this fight
5 down the road.
6 A word about Ms. Maxwell's…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…these
documents are confidential and should be kept under seal. Rule 26(c) of the Federal Rules of
Civil Procedure permits a district court to “make any order which justice requires to protect a
party or person from annoyance, embarrassment…
giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…Id.
Here, on the other hand, the Court has already issued an Order continuing the sealing of
information related to non-parties, and setting forth the procedure to challenge sealing, thereby
necessarily acknowledging that non-parties, in fact, do have…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.0
35 pg
…12. This concedes
that Maxwell will still enjoy all of the protections of the Federal Rules of Criminal Procedure and
Evidence, in addition to having the opportunity to raise objections to the Government’s evidence-
gathering process before Judge Nathan…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…it would become standard operating procedure,
19 and the resulting wholesale exposure of press files to
20 litigants' scrutiny would burden the press with heavy costs of
21 subpoena compliance and could otherwise impair its ability to
22 perform its…
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