giuffre-maxwell
gov.uscourts.nysd.447706.1130.0_3
1 pg
…Preska Counsel may proceed with filing the relevant
District Court Judge documents to the public docket, subject to the
United States District Court previously-ordered redactions. SO ORDERED.
Southern District of New York
500 Pearl Street …
giuffre-maxwell
gov.uscourts.nysd.447706.1201.0_2
1 pg
…279, 315, 320, and 335 (ECF No. 1167-2), as attachments hereto. Material
subject to this Court’s January 26, 2021, order remains redacted. ECF No. 1193.
Sincerely,
/s/ Sigrid McCawley
Sigrid S. McCawley, Esq.…
giuffre-maxwell
gov.uscourts.nysd.447706.1213.1
10 pg
…to
Unseal and redact only names and identifying information of Non-
Compel Production of
Parties who have objected to unsealing or whose time to object to
Documents Subject
unsealing has not yet expired.
to Improper Objection
344 …
giuffre-maxwell
gov.uscourts.nysd.447706.1198.0
1 pg
…279, 315, 320, and 335 (ECF No. 1167-2), as attachments hereto. Material
subject to this Court’s January 26, 2021, order remains redacted. ECF No. 1193.
Sincerely,
/s/ Sigrid McCawley
Sigrid S. McCawley, Esq.…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.0_2
1 pg
…279, 315, 320, and 335 (ECF No. 1167-2), as attachments hereto. Material
subject to this Court’s January 26, 2021, order remains redacted. ECF No. 1193.
Sincerely,
/s/ Sigrid McCawley
Sigrid S. McCawley, Esq.…
giuffre-maxwell
gov.uscourts.nysd.447706.1339.0
3 pg
…and, since that time, the
Court has received reports that information that was subject to
continued sealing was inadvertently disclosed. The Court writes
now to clarify the unsealing process intended by its December 18
Order.
First, the Court reiterates its…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.0
1 pg
…279, 315, 320, and 335 (ECF No. 1167-2), as attachments hereto. Material
subject to this Court’s January 26, 2021, order remains redacted. ECF No. 1193.
Sincerely,
/s/ Sigrid McCawley
Sigrid S. McCawley, Esq.…
giuffre-maxwell
gov.uscourts.nysd.447706.1036.0
2 pg
…Both Plaintiff Virginia Giuffre and Defendant Ghislaine Maxwell have asked for this
Court’s permission to file a List of Decided Motions under seal because the list contains
information that is currently subject to the Sealing Order in this case…
giuffre-maxwell
gov.uscourts.nysd.447706.592.0
5 pg
…deposition for any purpose permissible under the Federal Rules of Civil Procedure and
Federal Rules of Evidence. These designations are made subject to Ms. Maxwell’s previously
lodged objections to the various designations made by the Plaintiff and subject to…
giuffre-maxwell
gov.uscourts.nysd.447706.1.0
12 pg
…and abuse while
she was a minor child. Defendant Maxwell not only facilitated that sexual abuse but, most
recently, wrongfully subjected Giuffre to public ridicule, contempt and disgrace by, among other
things, calling Giuffre a liar in published statements with…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…be sealed. The Non-Parties shall include but are not limited to: (a) persons who produced or
answered discovery based upon the representation or understanding that the discovery would be
subject to the Protective Order previously issued in this action;…
giuffre-maxwell
gov.uscourts.nysd.447706.1278.0
4 pg
…were retained
to represent her in this matter. The privacy interests at stake in this litigation are the
subject of considerable complexity that Doe 171’s undersigned counsel are still
attempting to digest. Although Doe 171’s undersigned counsel still…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.1
4 pg
…be sealed. The Non-Parties shall include but are not limited to: (a) persons who
produced or answered discovery based upon the representation or understanding that the
discovery would be subject to the Protective Order previously issued in this action;…
giuffre-maxwell
gov.uscourts.nysd.447706.185.4
10 pg
…1).
Generally, they allege that the respondent Government violated their rights under the CVRA by
failing to consult with them before negotiating a non-prosecution agreement with Jeffrey Epstein,
who subjected them to various sexual crimes while they were minors. …
giuffre-maxwell
gov.uscourts.nysd.447706.1026.2
4 pg
…be sealed. The Non-Parties shall include but are not limited to: (a) persons who
produced or answered discovery based upon the representation or understanding that the
discovery would be subject to the Protective Order previously issued in this action;…
giuffre-maxwell
gov.uscourts.nysd.447706.962.0
7 pg
…the
Court explicitly ruled, “[A]ll documents, materials, and information subject to the Protective
Order must be returned to the party who designated its confidentiality as of the date this action
was dismissed.” Sealed Op., at 3 (Nov. 14, 2017) …
giuffre-maxwell
gov.uscourts.nysd.447706.1226.0
4 pg
…parties’ failure to properly make redactions of the
publicly released materials. In a series of orders, the Court has authorized the parties to release
certain Sealed Materials to the public subject to required redactions. However, the parties’
redactions are not…
giuffre-maxwell
gov.uscourts.nysd.447706.1044.0
13 pg
…be sealed. The Non-Parties shall include but are not limited to: (a) persons who
produced or answered discovery based upon the representation or understanding that the
discovery would be subject to the Protective Order previously issued in this action;…
giuffre-maxwell
gov.uscourts.nysd.447706.363.4
11 pg
…1).
Generally, they allege that the respondent Government violated their rights under the CVRA by
failing to consult with them before negotiating a non-prosecution agreement with Jeffrey Epstein,
who subjected them to various sexual crimes while they were minors. …
giuffre-maxwell
gov.uscourts.nysd.447706.1074.5
11 pg
…1).
Generally, they allege that the respondent Government violated their rights under the CVRA by
failing to consult with them before negotiating a non-prosecution agreement with Jeffrey Epstein,
who subjected them to various sexual crimes while they were minors. …
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