giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…various phrases, sentences or paragraphs were redacted. To determine
Case 1:15-cv-07433-LAP Document 1020 Filed 01/17/20 Page 2 of 7
Honorable Loretta A. Preska
November 16, 2019
Page 2
whether redaction was warranted, context…
giuffre-maxwell
gov.uscourts.nysd.447706.811.0
2 pg
…| Case No.: 15-cv-07433-RWS
Dear Judge Sweet:
Movant-Intervenor Michael Cernovich d/b/a Cernovich Media was previously unable to
divine from the publicly available portions of Plaintiff’s Notice of Intent to Request
Redaction (Doc No…
giuffre-maxwell
gov.uscourts.nysd.447706.833.0
4 pg
…counsel for Movant.
Now, Plaintiff has filed a Notice of Proposed Redactions to This Court’s Order Denying
Summary Judgment. Doc. No. 813. Movant does not know what is sought to be redacted or
why, as such was itself sealed…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.1
16 pg
…it should be redacted in the same way as DE
1090-32, but the redactions of the names of Non-Parties whose
time to object has expired should be removed.
Unseal and redact only names and identifying information of
Non…
giuffre-maxwell
gov.uscourts.nysd.447706.1010.0
3 pg
…15 Civ. 7433 (LAP)
Dear Judge Preska:
Paragraphs 2 and 3 of your October 28 Order require that the parties’ counsel conduct
a review of the sealed and redacted materials, confer and inform the Court by letter
about the identity…
giuffre-maxwell
gov.uscourts.nysd.447706.1226.0
4 pg
…22, 2020), https://slate.com/news-and-
politics/2020/10/ghislaine-maxwell-deposition-redactions-epstein-how-to-crack.html. In other
contexts, the subject matter of the publicly disclosed excerpts allows the identification of the
redacted name. See, e.g…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…s deposition. Plaintiff
fails to mention that DE 172’s redactions also include purported “summaries” of Doe 162’s
deposition and the purported anticipated deposition testimony of Doe 84 (whose name and
testimony the Second Circuit redacted in Brown). Both…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.2
4 pg
…it should remained
sealed/redacted, (3) if it is a judicial document, (a) the weight of presumption of public access
that should be afforded itto the document, (b) the identification and weight of any countervailing
interests supporting continued sealing/redaction…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.1
7 pg
…document with applicable Brown
224
minimal redactions (if any) and redactions of yet-to-be-noticed
Non-Party names (if any)
199: Plaintiff’s Motion N/A (not currently sealed or redacted)
for Extension of Time
to Complete
Depositions
…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…submissions, make appropriate
redactions, e.g., the Non-Party’s identifying information (with the assistance of the
Original Parties, as appropriate), substitute Non-Party pseudonymous identifiers as
appropriate, redact the submission as appropriate, and file them as redacted via
ECF…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.1
4 pg
…4
redactions, e.g., the Non-Party’s identifying information (with the assistance of the
Original Parties, as appropriate), substitute Non-Party pseudonymous identifiers as
appropriate, redact the submission as appropriate, and file them as redacted via ECF,
identifying the…
giuffre-maxwell
gov.uscourts.nysd.447706.1025.0
17 pg
…document, whether it should remained sealed/redacted, (3) if it is a judicial document,
(a) the weight of presumption of public access that should be afforded it, (b) the identification
and weight of any countervailing interests supporting continued sealing/redaction…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.0
16 pg
…submissions, make appropriate
redactions, e.g., the Non-Party’s identifying information (with the assistance of the
Original Parties, as appropriate), substitute Non-Party pseudonymous identifiers as
appropriate, redact the submission as appropriate, and file them as redacted via
ECF…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.1
7 pg
…make appropriate
redactions, e.g., the Non-Party’s identifying information (with the assistance of the
Original Parties, as appropriate), substitute Non-Party pseudonymous identifiers as
appropriate, redact the submission as appropriate, and file them as redacted via ECF,
identifying…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…for a non-merits purpose, e.g., the confidentiality,
discoverability or admissibility of information, should remain sealed or redacted if there is any
interest in sealing or redaction. See TheSreet.Com, 273 F.3d at 233. The references to the…
giuffre-maxwell
gov.uscourts.nysd.447706.1044.0
13 pg
…make appropriate
redactions, e.g., the Non-Party’s identifying information (with the assistance of the
Original Parties, as appropriate), substitute Non-Party pseudonymous identifiers as
appropriate, redact the submission as appropriate, and file them as redacted via ECF,
identifying…
giuffre-maxwell
gov.uscourts.nysd.447706.1108.0
5 pg
…make appropriate
redactions, e.g., the Non-Party’s identifying information (with the assistance of the
Original Parties, as appropriate), substitute Non-Party pseudonymous identifiers as
appropriate, redact the submission as appropriate, and file them as redacted via ECF,
identifying…
giuffre-maxwell
gov.uscourts.nysd.447706.892.0
11 pg
…2016) ; see also March 22 , 2017 Redacted Opinion on
Defendant ' s Motion for Summary Judgment , ECF No. 872 .
2
Case 1:15-cv-07433-RWS Document 892 Filed 05/03/17 Page 3 of 11
At issue is the…
giuffre-maxwell
gov.uscourts.nysd.447706.1353.0
6 pg
…seal; by virtue of their sealing,
the Government does not know which specific documents have been filed under seal.
The Act requires the Government to produce publicly the Materials, subject to certain re-
dactions and/or withholdings. In particular, subject…
giuffre-maxwell
gov.uscourts.nysd.447706.1034.0
16 pg
…make appropriate
redactions, e.g., the Non-Party’s identifying information (with the assistance of the
Original Parties, as appropriate), substitute Non-Party pseudonymous identifiers as
appropriate, redact the submission as appropriate, and file them as redacted via ECF,
identifying…
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