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.447706.941.0
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.447706.1228.0
4 pg
…of our letter, we were directed to the Court’s October 20, 2020
Order, issued in the context of the Court’s consideration of the Sealed Records pertaining to
Does No. 1 and 2. See DE 1157. In that Order…
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.447706.1156.0
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.447706.1250.0
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.447706.1167.2
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.447706.1219.8
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.447706.1256.23
4 pg
7. Attached hereto as Sealed Composite Exhibit 5 are true and correct copies of
Excerpts from the June 1, 2016 Deposition of John Alessi.
8. Attached hereto as Sealed Exhibit 6 is a true and correct copy of June 20…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.0
18 pg
…P.C., counsel of record for Defendant
Ghislaine Maxwell (“Maxwell”) in this action. I respectfully submit this declaration in
support of Ms. Maxwell’s Reply In Support of Her Objection to Unsealing Sealed Material.
2. Attached as Exhibit A (filed…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.0
56 pg
…Haddon, Morgan & Foreman, P.C., counsel of record for Defendant
Ghislaine Maxwell (“Maxwell”) in this action. I respectfully submit this declaration in
support of Ms. Maxwell’s Objections to Unsealing Sealed Materials Related to Docket
Entries 231, 279, 315, 320…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.44_1
3 pg
…3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of Judith Lightfoot
Redacted Medical Records (Giuffre005431-005438).
4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of Judith
Lightfoot’s June 27…
giuffre-maxwell
gov.uscourts.nysd.447706.1209.0
3 pg
…Haddon, Morgan & Foreman, P.C., counsel of record for Defendant
Ghislaine Maxwell (“Maxwell”) in this action. I respectfully submit this declaration in
support of Ms. Maxwell’s Objections to Unsealing Sealed Materials Related to Docket
Entries 345, 356, 362, 370…
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.447706.980.0
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.447706.1092.0
1 pg
…2020 (ECF No. 1091), Plaintiff is filing
renewed versions of the materials previously sealed at ECF Nos. 235-13 and 249-13 as attachments
hereto.
Sincerely,
/s/ Sigrid S. McCawley
Sigrid S. McCawley,…
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…
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