giuffre-maxwell
gov.uscourts.nysd.447706.1226.0
4 pg
…contained within the Sealed Records. See DE at
1224, at 5. Plaintiff and Defendant each generously designated materials as confidential under
the Protective Order, and the process of determining what excerpts to unseal from such a
voluminous record is necessarily…
giuffre-maxwell
gov.uscourts.nysd.447706.1167.0
31 pg
…unsealing Unseal.
Note: Original Parties agree.
Keep sealed (medical records).
270-1 7.8.16 No objection to unsealing
…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…her response chart that she objected to unsealing her medical
records. (DE 1073 at 19-20) Without explanation, the Court presumably recognized that
plaintiff relied on the Protective Order when disclosing confidential materials, kept sealed
numerous records related to Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.0
35 pg
…6 Unseal but redact medical information and addresses.
258-7 Unseal but redact tax returns and addresses.
258-8 Keep sealed (medical records).
Unseal and redact only names and identifying information of
Non-Parties who have objected to unsealing or…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…publicly
disseminate such reports? Where did she obtain these reports? Was it “theft” of “sealed juvenile
records” for her to have those police reports?
It would seem the juveniles referenced in the reports filed by Plaintiff, juveniles who
have never…
giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…2 (S.D.N.Y. May 16, 2006)
(noting state court records sealed to protect privacy of sexual assault victim pursuant to Section 50-b of the N.Y.
Civil Rights Law), report and recommendation adopted, 2006 WL 1763678 (June…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…must remain sealed.
IV. Plaintiff applies a different standard to her own request to keep records sealed.
Plaintiff asks this Court to keep her medical records (and other records on her chart)
sealed without providing any basis for the request…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.6_1
14 pg
…publicly
disseminate such reports? Where did she obtain these reports? Was it “theft” of “sealed juvenile
records” for her to have those police reports?
It would seem the juveniles referenced in the reports filed by Plaintiff, juveniles who
have never…
giuffre-maxwell
gov.uscourts.nysd.447706.1167.2
27 pg
…unsealing Unseal.
Note: Original Parties agree.
Keep sealed (medical records).
270-1 7.8.16 No objection to unsealing
…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.1
16 pg
…6 Unseal but redact medical information and addresses.
258-7 Unseal but redact tax returns and addresses.
258-8 Keep sealed (medical records).
Unseal and redact only names and identifying information of
Non-Parties who have objected to unsealing or…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…parties that should remain permanently sealed. 1 First,
discovery materials, including written responses and deposition transcripts, or excerpts of the
same, that were not relevant to the performance of Article III functions, are not judicial records,
are entitled to no…
giuffre-maxwell
gov.uscourts.nysd.447706.977.2
1 pg
…judgment record ourselves. I agree that all or most of the material
must be unsealed. Nevertheless, in my view, the district court is better suited to
the task. As the Court’s opinion recognizes in connection with the remaining
sealed…
giuffre-maxwell
gov.uscourts.nysd.447706.968.1
1 pg
…judgment record ourselves. I agree that all or most of the material
must be unsealed. Nevertheless, in my view, the district court is better suited to
the task. As the Court’s opinion recognizes in connection with the remaining
sealed…
giuffre-maxwell
gov.uscourts.nysd.447706.1148.0
1 pg
…15 Civ. 7433 (LAP)
Dear Judge Preska:
This is a letter motion seeking leave to permit Ms. Maxwell to file a redacted Memorandum of
Law in Support of Objections to Unsealing Sealed Materials Related to DEs 231, 279, 315,
320…
giuffre-maxwell
gov.uscourts.nysd.447706.1168.0_2
2 pg
…15 Civ. 7433 (LAP)
Dear Judge Preska:
This is a letter motion seeking leave to permit Ms. Maxwell to file a redacted Reply
Memorandum of Law in Support of Objections to Unsealing Sealed Materials Related to DEs
231, 279, 315…
giuffre-maxwell
gov.uscourts.nysd.447706.1082.0
1 pg
…Maxwell to file a redacted Letter to the
Court and her proposed redactions to Sealed Materials under seal.
The Protective Order governing this case states:
Whenever a party seeks to file any document or material containing CONFIDENTIAL
INFORMATION with the…
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.447706.1072.0
1 pg
…Maxwell to file a redacted Reply In
Support of Her Objections to Unsealing Sealed Materials and to file under seal Exhibits A-D
thereto.
The Protective Order governing this case states:
Whenever a party seeks to file any document or…
giuffre-maxwell
gov.uscourts.nysd.447706.1152.0
1 pg
…15 Civ. 7433 (LAP)
Dear Judge Preska:
This is a letter motion seeking leave to permit Ms. Maxwell to file a redacted Memorandum of
Law in Support of Objections to Unsealing Sealed Materials Related to DEs 231, 279, 315,
320…
giuffre-maxwell
gov.uscourts.nysd.447706.1075.0
1 pg
…Maxwell to file a redacted Reply In
Support of Her Objections to Unsealing Sealed Materials and to file under seal Exhibits A-D
thereto.
The Protective Order governing this case states:
Whenever a party seeks to file any document or…
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