giuffre-maxwell
gov.uscourts.nysd.447706.1320.8
12 pg
…L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S NON-REDACTED MOTION FOR LEAVE TO SERVE THREE
DEPOSITION SUBPOENAS BY MEANS OTHER THAN PERSONAL SERVICE
Plaintiff Virginia Giuffre, by and…
giuffre-maxwell
1320-8
12 pg
…L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S NON-REDACTED MOTION FOR LEAVE TO SERVE THREE
DEPOSITION SUBPOENAS BY MEANS OTHER THAN PERSONAL SERVICE
Plaintiff Virginia Giuffre, by and…
giuffre-maxwell
gov.uscourts.nysd.447706.160.0
12 pg
…L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S REDACTED MOTION FOR LEAVE TO SERVE THREE DEPOSITION
SUBPOENAS BY MEANS OTHER THAN PERSONAL SERVICE
Plaintiff Virginia Giuffre, by and throug…
giuffre-maxwell
gov.uscourts.nysd.447706.981.0
2 pg
…Dear Judge Preska:
Intervenor Michael Cernovich d/b/a Cernovich Media originally sought to intervene and
unseal the wholly-redacted summary judgment documents filed by Defendant Ghislaine
Maxwell and the subsequent summary judgment documents that would be filed relative
to…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.26
5 pg
… At the top of that document, about
14 three lines down, you see the redacted
15 portions where there is black so it blacks
16 out the name.
17 A. I see black redacted portions.
18 Q. That's a…
giuffre-maxwell
gov.uscourts.nysd.447706.1351.0
32 pg
…right of access to parts
of judicial documents containing identifying information; (5) declining to
make public the redacted list of all pseudonymized third-parties used by the
district court in its unsealing review; and (6) declining to make public
certain…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.9
18 pg
…the event the Court grants my application, I would also request that the Court
unseal the Requested Documents along with all of the references to them in my motion papers
that are being redacted from the public docket.
4. As…
giuffre-maxwell
gov.uscourts.nysd.447706.1349.0
31 pg
…right of access to parts
of judicial documents containing identifying information; (5) declining to
make public the redacted list of all pseudonymized third-parties used by the
district court in its unsealing review; and (6) declining to make public
certain…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.4
106 pg
…Ms. Maxwell, the redacted
4 MR. PAGLIUCA: I'm going to object 4 information is redacted because it reveals
5 to you interrupting the witness who was 5 the name of a minor, someone who is under the
6 answering…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.5
465 pg
…report, Ms. Maxwell, the redacted
4 information is redacted because it reveals
5 the name of a minor, someone who is under the
6 age of 18.
7 On page 28, in the third paragraph,
8 about halfway down, it…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.17
13 pg
…their possession, custody and control
that have not been filed with the Court.
In April 2018 a Miami Herald journalist and the Herald (collectively “the Miami
Herald”) moved to unseal all sealed and redacted documents filed with the Court. Doc…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.1
465 pg
…report, Ms. Maxwell, the redacted
4 information is redacted because it reveals
5 the name of a minor, someone who is under the
6 age of 18.
7 On page 28, in the third paragraph,
8 about halfway down, it…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…privileged.
13 We just received an opposition to our motion which was
14 filed last night after close of business and we've been
15 reviewing it, but much of the substance of it is redacted out
16 pursuant, presumably…
giuffre-maxwell
gov.uscourts.nysd.447706.503.0
21 pg
…the Subpoena is quashed.
The parties are directed to joint ly file a proposed
redacted version of this Opinion consistent with the Protective
Order or notify the Court that none are necessary within two
weeks of the date of receipt…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.13_5
465 pg
…report, Ms. Maxwell, the redacted
4 information is redacted because it reveals
5 the name of a minor, someone who is under the
6 age of 18.
7 On page 28, in the third paragraph,
8 about halfway down, it…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…memoranda of law and
supporting exhibits contesting this motion under seal. On March 22,
2017, the District Court denied the motion in a heavily redacted 76‐
page opinion. Once again, the entire summary judgment record,
including the unredacted version of…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.19
106 pg
…Ms. Maxwell, the redacted
4 MR. PAGLIUCA: I'm going to object 4 information is redacted because it reveals
5 to you interrupting the witness who was 5 the name of a minor, someone who is under the
6 answering…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.2
70 pg
…state unless permission is granted by sender .. If you are the intended recipient, be aware that your use of any confidential or persona
information may be restricted by state and federal privacy laws. If you, the reader of this message…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.28
38 pg
…Ms. Maxwell, the redacted
4 MR. PAGLIUCA: I'm going to object 4 information is redacted because it reveals
5 to you interrupting the witness who was 5 the name of a minor, someone who is under the
6 answering…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…memoranda of law and
supporting exhibits contesting this motion under seal. On March 22,
2017, the District Court denied the motion in a heavily redacted 76‐
page opinion. Once again, the entire summary judgment record,
including the unredacted version of…
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