giuffre-maxwell
gov.uscourts.nysd.447706.1324.0
1 pg
…and 1320-40 in the
above-captioned case because they contain personally identifiable
information, the disclosure of which could threaten the safety and
privacy of named individuals. Counsel shall redact the personally
identifiable information and re-file the stricken documents…
giuffre-maxwell
gov.uscourts.nysd.447706.57.3
39 pg
…the incident.
It included interviews conducted, the outcome of the investigations the operator
of the site undertook as part of the safety management system it was required to
have by the COMAH Regulations, and the reports of the accident investigation
…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…harass and intimidate Ms. Giuffre who was a victim of sexual trafficking.
a. Due to safety concerns with respect to Ms. Giuffre and her minor children,
she is not at liberty to reveal her present residential location. To ensure that…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…
Has not had a haircut in a year and is being moved ‘from cell-to-cell’ for her own
safety.
2/13
Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 45 of 161…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.3
223 pg
…notice anything to my
20 law office for Virginia. She's had some safety
21 issues with respect to her location so we're not
22 going to be putting that on the record.
23 MS. BORJA: That's fine…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…whether she will reveal here address to Defendant’s counsel
confidentially and we will update you with her response.
a. Due to safety concerns with respect to Ms. Giuffre and her minor children,
she is not at liberty to reveal…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.40
19 pg
…Royal Palm Beach (Florida) Police Department, the
County Court in and for Palm Beach County (Florida), the Greenacres
(Florida) Department of Public Safety, and the Fremont County (Colorado)
Sheriff’s Office.
9. Employment records obtained from ET Employment Training and…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…presumption under the common law may be
overcome by demonstrating that sealing serves to further other
"substantial interests," such as "a third party's personal
privacy interests, the public's safety, or preservation of
attorney-client privilege." Under Seal v…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…
Unfortunately, I cannot send you the footage without her consent due to massive consequences to
her safety but I can confirm that I do have footage in my possession. I have backed up the footage
on several USB sticks and…
giuffre-maxwell
gov.uscourts.nysd.447706.63.0
22 pg
…known Prime
Minister and other world leaders.” Plaintiff refused, claiming every applicable privilege, and
additionally “because naming some such individuals would jeopardize her physical safety based
on credible threats to the same (sic).” Menninger Decl. Ex. A at 12-13…
giuffre-maxwell
gov.uscourts.nysd.447706.78.0
30 pg
…receiving
Defendant’s Motion to Compel.
7
Case 1:15-cv-07433-LAP Document 78 Filed 04/04/16 Page 13 of 30
because she had received credible threats to her safety and was concerned about revealing her
location…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
… Martindell, 594 F.2d at 295-97. The
courts have an obligation to safeguard the integrity of criminal investigations and the privacy and
safety of witnesses and suspects that are part of those investigations. United States v. Longueuil,
567 F…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.12
223 pg
…notice anything to my
20 law office for Virginia. She's had some safety
21 issues with respect to her location so we're not
22 going to be putting that on the record.
23 MS. BORJA: That's fine…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…whether she will reveal here address to Defendant’s counsel
confidentially and we will update you with her response.
a. Due to safety concerns with respect to Ms. Giuffre and her minor children,
she is not at liberty to reveal…
giuffre-maxwell
1320-40
19 pg
…Royal Palm Beach (Florida) Police Department, the
County Court in and for Palm Beach County (Florida), the Greenacres
(Florida) Department of Public Safety, and the Fremont County (Colorado)
Sheriff’s Office.
9. Employment records obtained from ET Employment Training and…
giuffre-maxwell
gov.uscourts.nysd.447706.71.3
40 pg
…harass and intimidate Ms. Giuffre who was a victim of sexual trafficking.
a. Due to safety concerns with respect to Ms. Giuffre and her minor children,
she is not at liberty to reveal her present residential location. To ensure that…
giuffre-maxwell
gov.uscourts.nysd.447706.42.0
7 pg
…July 20, 2015) (denying motion to compel
response to interrogatory that required identification of all documents that “relate to”
drills or safety security training exercises “over a decade long span,” and holding that
interrogatory was “facially overbroad, and potentially sweep…
giuffre-maxwell
gov.uscourts.nysd.447706.589.0
24 pg
…298 (2d Cir. 2011) cuts
against Cernovich’s argument as the Court stated: “Accordingly, we have recognized that “a
person's physical safety” as well as “the privacy interests of individuals” such as witnesses, third
parties, and those investigated in…
giuffre-maxwell
gov.uscourts.nysd.447706.75.0
31 pg
…C. Plaintiff improperly refuses to disclose her address under Local Rule 26.1
Plaintiff has refused to disclose her residential address, even with a Protective Order in
place, “[d]ue to safety concerns.” Menninger Decl., Ex. A at 5. This…
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