giuffre-maxwell
gov.uscourts.nysd.447706.941.0
6 pg
…filing the document. The only exceptions are if the entire action
has been placed under seal or a judge has signed the sealing envelope and submits
it directly to the sealed records clerk.
See Sealed Records Filing Instructions, U.S…
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…above-captioned action
pursuant to Rule 24 of the Federal Rules of Civil Procedure and
(2) should intervention be permitted, for confidential access to
sealed judicial records and discovery documents. (See Notice of
Ex Parte Motion to Intervene and for …
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.447706.1320.17
25 pg
…when, and by whom such reports (or descriptions of reports) were
obtained from a minor child’s sealed juvenile records and files.
RESPONSE: Ms. Maxwell objects to this Request in that there is no “Interrogatory No.
1” to which the…
giuffre-maxwell
1320-17
25 pg
…when, and by whom such reports (or descriptions of reports) were
obtained from a minor child’s sealed juvenile records and files.
RESPONSE: Ms. Maxwell objects to this Request in that there is no “Interrogatory No.
1” to which the…
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.447706.1156.1
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.447706.1219.8
29 pg
…false accusations. In the same article, Plaintiff’s counsel Sigrid McCawley’s claimed Plaintiff
was “‘victimized all over again with [the New York Daily News’ access to] the leak of sealed
juvenile records.’” Id. (GM_00121) (emphasis supplied). Notably neither…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 26 of 40
request as it seeks documents of sealed juvenile records, and the only means of obtaining
such records are either through court order or illegal means…
giuffre-maxwell
gov.uscourts.nysd.447706.71.3
40 pg
…15-cv-07433-RWS Document 71-3 Filed 03/23/16 Page 26 of 40
request as it seeks documents of sealed juvenile records, and the only means of obtaining
such records are either through court order or illegal means…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.1
18 pg
…documents concerning how, when, and by whom such reports (or descriptions of
reports) were obtained from a minor child’s sealed juvenile records and files.
Response: Ms. Maxwell objects to this Request in that there is no “Interrogatory No. 1”…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…to shield perpetrators of heinous acts. If TGP is not permitted to intervene and
view the Epstein Client List, to the extent it can be ascertained from records remaining sealed, it
will suffer great impairment, as it cannot perform their…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…CONFIDENTIAL ACCESS TO JUDICIAL RECORDS AND DISCOVERY
DOCUMENTS
The Government of the United States Virgin Islands (the “USVI”) moves to intervene in
this action for the limited purpose of obtaining confidential access to both: (a) all sealed
documents related to…
giuffre-maxwell
gov.uscourts.nysd.447706.1122.0_2
13 pg
…IN SUPPORT OF EX PARTE MOTION
TO INTERVENE AND FOR CONFIDENTIAL ACCESS TO
JUDICIAL RECORDS AND DISCOVERY DOCUMENTS
Case 1:15-cv-07433-LAP Document 1122 Filed 09/24/20 Page 2 of 13
The Government of the United…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…Notably, many of the documents were sealed in the first instance at the
request of Plaintiff and her counsel. And as to, for example, Plaintiff’s medical records, no one
interposed any objection to their unsealing until Plaintiff’s belated…
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.447706.1330.15
43 pg
…43
COMPOSITE
EXHIBIT 1
(File Under Seal)
Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 2 of 43
Case 9:16-mc-81608-DMM *SEALED* Document 4
of 6
United States District Court…
giuffre-maxwell
gov.uscourts.nysd.447706.1264.0
1 pg
…DE 1258, at 1. The Court should deny TGP’s motion to intervene and unseal.
This Court has implemented a carefully calibrated unsealing protocol that advances Your
Honor’s individualized review of each sealed docket entry. See e.g., DEs…
giuffre-maxwell
gov.uscourts.nysd.447706.1240.0
5 pg
…the record for this Court to continue to seal any of the documents
concerning Does 17, 53, 54, 56, 73, 93, or 151, and these documents should be unsealed in their
entirety.
The party requesting that documents remain sealed bears…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…On June 20, 2016, this Court
Ordered Defendant to sit for a second deposition because her refusal to answer questions posed
in her first Deposition (June 20, 2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,…
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