giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
… Intervenors’ First Proposition of Law: For minor victims of sexual abuse, “redactions
should be applied sparingly to shield only information that would identify those who
have not already been publicly identified.” DE 1248, at 2.
The Reality: Courts routinely seal…
giuffre-maxwell
gov.uscourts.nysd.447706.1135.0_6
1 pg
…October 21, 2020
Honorable Loretta A. Preska
United States District Court
Southern District of New York
500 Pearl Street
New York, NY 10007
Re: Proposed Redactions to Sealed Materials Related to Non-Parties
Giuffre v. Ghislaine Maxwell, No. 15 Civ…
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.447706.1242.0
9 pg
…there is an error and that Plaintiff does not dispute that assertion. Plaintiff merely
contends that any redactions be narrowly tailored to address the countervailing interests Doe 54
raised.
II. Does 55 and 56 Have Not Rebutted the Presumption in…
giuffre-maxwell
gov.uscourts.nysd.447706.1248.0
6 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.1
16 pg
…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-Parties who have objected to unsealing or whose time to
…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.3_2
12 pg
…ghislaine-maxwell-testimony-jeffrey-epstein-released-2020-10
19 https://slate.com/news-and-politics/2020/10/ghislaine-maxwell-deposition-redactions-epstein-how-to-crack.html
20 https://www.independent.co.uk/news/world/ghislaine-maxwell-deposition-jeffrey-epstein-accuser…
giuffre-maxwell
gov.uscourts.nysd.447706.851.0
158 pg
…7 allegations concerning sexual abuse and the activities of the
8 defendant. I think that's my sense of my own opinion.
9 Yesterday, we were discussing the redactions of the
10 intervention motion. I got the sense, perhaps wrongly…
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.447706.1247.0
25 pg
…at 7:9–12, 21–23 (“[W]hat we are looking for from you is a specific
explanation of why the document should remain sealed or the redactions should continue specific
to that document. I think that’s what the…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…corrected, six-page brief.
2
Case 1:15-cv-07433-LAP Document 1068 Filed 06/24/20 Page 7 of 24
explanation of why the document should remain sealed or the redactions should continue specific
to that document. I…
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.447706.1073.0
22 pg
…weight of presumption of
public access that should be afforded to an item, (b) the identification and weight of any
countervailing interests supporting continued sealing/redaction of the item, and (c) whether the
countervailing interests rebut the presumption of public…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.4
106 pg
…25 corner.
Page 23 Page 25
1 G Maxwell - Confidential 1 G Maxwell - Confidential
2 Q. I'm not talking about friends. I'm 2 You will see some redactions in
3 talking about individuals -- …
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1237.0
20 pg
…at 7:9–12, 21–23 (“[W]hat we are looking for from you is a specific
explanation of why the document should remain sealed or the redactions should continue specific
to that document. I think that’s what the…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.5
465 pg
…on the top right-hand
25 corner.
Case 1:15-cv-07433-LAP Document 1307-5 Filed 08/25/23 Page 26 of 465
Page 25
1 G Maxwell - Confidential
2 You will see some redactions in
3 this report…
giuffre-maxwell
gov.uscourts.nysd.447706.1284.0
17 pg
…criminal
19 trial.
20 About six documents concerning Doe number 28,
21 Ms. Giuffre supports the unsealing except for the redaction of
22 Doe 28's name. Plaintiff takes no position as to approximately
23 26 of the documents.
24 …
giuffre-maxwell
gov.uscourts.nysd.447706.1283.0
17 pg
…criminal
19 trial.
20 About six documents concerning Doe number 28,
21 Ms. Giuffre supports the unsealing except for the redaction of
22 Doe 28's name. Plaintiff takes no position as to approximately
23 26 of the documents.
24 …
giuffre-maxwell
gov.uscourts.nysd.447706.1335.1
465 pg
…on the top right-hand
25 corner.
Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 26 of 465
Page 25
1 G Maxwell - Confidential
2 You will see some redactions in
3 this report…
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