giuffre-maxwell
gov.uscourts.nysd.447706.1087.0
4 pg
…Defendant Ghislaine Maxwell’s
letter dated July 30, seeking to submit under seal her proposed
redactions to the materials ordered unsealed by the Court’s July
23 Order and raising issues with proposed redactions submitted by
Plaintiff Virginia Giuffre. (Dkt…
giuffre-maxwell
gov.uscourts.nysd.447706.434.0
1 pg
…Street
New York, NY 10007
Re: Giuffre v. Maxwell
Case no. 15-cv-07433-RWS-Regarding Redactions in Sealed Opinion
Regarding Subpoena to Paul G. Cassell
Dear Judge Sweet,
On August 30, 2016, the Court issues a ruling on Cassell…
giuffre-maxwell
gov.uscourts.nysd.447706.264.0
3 pg
…hereby files with the Court a proposed redacted version of its
June 20, 2016, Opinion with agreed upon redactions. The Court ordered as follows:
This matter being subject to a Protective Order, the parties are directed to meet and
confer…
giuffre-maxwell
gov.uscourts.nysd.447706.1157.0_1
5 pg
…Non-Party Notice to all remaining Non-Parties was to
expedite the review process by minimizing the number of
redactions applied at each round and allowing the Court to have
more clarity on which Non-Parties were actually objecting to…
giuffre-maxwell
gov.uscourts.nysd.447706.1318.0
3 pg
…her
current country, the Parties and the Miami Herald consent to
redacting Doe 107's name and any personally identifying
information in the docket entries that the Court previously
ordered unsealed. Giuffre's and the Miami Herald's consent to…
giuffre-maxwell
gov.uscourts.nysd.447706.1038.0
2 pg
…orders.
Second, Defendant proposes that paragraph 3(e) be deleted in its entirety. Plaintiff
disagrees. This paragraph allows the Court to determine what redactions are appropriate, in
consultation with the parties, before filing Non-Parties’ objections on the docket. To…
giuffre-maxwell
gov.uscourts.nysd.447706.1107.0
2 pg
…may be made ad hoc.
5. Proposed Redactions: The Court will not require the Original
Parties to include with any brief in support of unsealing a
sealed set of proposed redactions for in camera review.
6. Appeals: Counsel for Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1317.0
3 pg
…her
current country, the Parties and the Miami Herald consent to
redacting Doe 107's name and any personally identifying
information in the docket entries that the Court previously
ordered unsealed. Giuffre's and the Miami H…
giuffre-maxwell
gov.uscourts.nysd.447706.1129.0_5
2 pg
…to confirm that her
counsel may release “later today” the previously unsealed deposition testimony of Ms.
Maxwell and Doe 1 (“Unsealed Materials”), while redacting Doe 1’s name from the materials
that will be filed. We oppose Plaintiff’s request…
giuffre-maxwell
gov.uscourts.nysd.447706.1231.0
3 pg
…the public docket in the unsealing protocol dated August 27, 2020:
The Court’s staff will receive Non-Party submissions, make appropriate redactions,
e.g., the Non-Party’s identifying information (with the assistance of the Original
Parties, as appropriate)…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…Epstein’s residence in Florida and uncovered his
house message pads. The message pads reveal that in 2004, Maxwell was coordinating
“training” with underage girls as indicated by the redactions in the message pads. See
McCawley Decl. at Exhibit 6…
giuffre-maxwell
gov.uscourts.nysd.447706.1188.0
3 pg
…640. Although there are
more than five DEs to consider, some of them are short and without significant
redactions.
2. Alternatively (not additionally), the Court could circle back and consider any Non-
Party objections to the pleadings already briefed and…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…reports at
issue by interposing a simple request to the law enforcement agency and paying any applicable
4
Case 1:15-cv-07433-LAP Document 1328-20 Filed 01/05/24 Page 7 of 14
copying and redaction fees…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…month, this Court sought even greater strictures regarding the Protective Order.25
Furthermore, as this Court will remember, it twice allowed the parties to submit
suggested redactions to the public versions of its Orders (DE 135; June 20, 2016, Order26…
giuffre-maxwell
gov.uscourts.nysd.447706.1050.0
12 pg
…Ms.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 1050 Filed 04/15/20 Page 4 of 12 4
K3VQgiuC
1 McCawley the redactions that she proposes, and I think we are…
giuffre-maxwell
gov.uscourts.nysd.447706.1312.0
9 pg
…621, 628–30 (S.D.N.Y. 2011). 3
3
Following Brown, minimal redactions have been applied to (1) “personally identifying
information such as personal phone numbers, contact lists, birth dates, and social security
numbers”; (2) “the names of alleged…
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.447706.1099.0
4 pg
…requested Excerpts (and who therefore do not intend to object to
unsealing) will also be exceedingly helpful to the Original Parties tasked with redacting the names
of Non-Parties who have not yet had the opportunity to object to unsealing…
giuffre-maxwell
gov.uscourts.nysd.447706.1021.0
18 pg
…and that's the letter in
2 which she notes the various reasons for maintaining the sealed
3 or redactions of the sealed materials and she lists a group of
4 countervailing factors including privacy ancillary court
5 submissions and…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…has her name redacted. Of course, such a redaction does Ms. Giuffre little good when
Defendant and her cohorts distribute it to the press - the identity of the victim in the police report
will presumably be supplied by Defendant. Indeed…
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