giuffre-maxwell
gov.uscourts.nysd.447706.1169.0_1
1 pg
…No. 1167-1. For the avoidance of any doubt, Defendant submitted her
proposed redactions on her own, and Plaintiff was not consulted about the redactions nor does she
agree with the redactions.
Sincerely,
/s/ Sigrid S. McCawley
…
giuffre-maxwell
gov.uscourts.nysd.447706.1087.0
4 pg
…Defendant Ghislaine Maxwell’s
letter dated July 30, seeking to submit under seal her proposed
redactions to the materials ordered unsealed by the Court’s July
23 Order and raising issues with proposed redactions submitted by
Plaintiff Virginia Giuffre. (Dkt…
giuffre-maxwell
gov.uscourts.nysd.447706.1237.1
6 pg
…Doe 54, J. Doe Unseal and redact only names and identifying information of Non-
53 Parties who have submitted an objection not yet ruled on. Note:
Does 53 and 54 do not object to unsealing.
150-1 J. Doe 54…
giuffre-maxwell
gov.uscourts.nysd.447706.1049.0
91 pg
…LAP)
-against-
ORDER
GHISLAINE MAXWELL,
Defendant.
LORETTA A. PRESKA, Senior United States District Judge:
The Court has reviewed and approved the parties’ joint proposed
redacted Decided Motions List that was submitted to the Court on
April 3, 2020. (See dkt…
giuffre-maxwell
gov.uscourts.nysd.447706.1351.0
32 pg
…Defendant – Appellee.
_______________________________________
The appeals in the above captioned cases from orders of the United States District Court
for the Southern District of New York were submitted on the district court’s record and the
parties’ briefs.
IT IS HEREBY ORDERED…
giuffre-maxwell
gov.uscourts.nysd.447706.721.0
3 pg
…Order. See
Plaintiff’s redactions attached hereto as Sealed Exhibit 1.
Dated: March 15, 2017
Respectfully Submitted,
/s Meredith Schultz
By:
Sigri…
giuffre-maxwell
gov.uscourts.nysd.447706.1253.0
12 pg
…Virginia Giuffre
files this Reply to Non-Parties 28, 97 and 144’s Objections to unsealing.
PRELIMINARY STATEMENT
Does 12, 28, 97, and 144 have submitted replies in response to Plaintiff’s March 18, 2022
brief. Dkt. 1247. Does 147…
giuffre-maxwell
gov.uscourts.nysd.447706.1196.0
32 pg
…are relevant to the Court's
7 exercise of its inherent supervisory powers. The documents at
8 issue here were submitted in connection with discovery motions
9 decided by Judge Sweet. The Court concludes that they are
10 judicial documents…
giuffre-maxwell
gov.uscourts.nysd.447706.1148.0
1 pg
…materials remain under seal.
Ms. Maxwell intends to file the redacted version of the Memorandum publicly on ECF and
seeks leave only to file the unredacted version and Exhibit D under seal.
Respectfully submitted,
Laura A. Menninger
CC: Counsel of…
giuffre-maxwell
gov.uscourts.nysd.447706.1021.0
18 pg
…this review.
15 THE COURT: Bless you, my daughter.
16 MS. McCAWLEY: A few ideas that we have come up
17 with -- we have submitted the letter to you, obviously, which
18 poses an approach dealing with the non-parties…
giuffre-maxwell
gov.uscourts.nysd.447706.1220.0
17 pg
…at issue here, unless otherwise mentioned, were
7 submitted in connection with discovery motions decided by Judge
8 Sweet. The parties and nonparties dispute whether certain of
9 the documents at issue today are judicial documents.
10 First, docket number…
giuffre-maxwell
gov.uscourts.nysd.447706.1242.0
9 pg
…55, and 56’s Objections to unsealing docket entries containing
references to them.
PRELIMINARY STATEMENT
Only Non-Party Does 54, 55, and 56 have submitted reply submissions in response to
Plaintiff’s opening brief filed on January 12, 2022. Dkt…
giuffre-maxwell
gov.uscourts.nysd.447706.1284.0
17 pg
…connection with a decided
6 motion or papers that are relevant to the Court's exercise of
7 its inherent supervisory powers.
8 The documents at issue here were submitted in
9 connection with discovery motions decided by Judge Sweet…
giuffre-maxwell
gov.uscourts.nysd.447706.1283.0
17 pg
…connection with a decided
6 motion or papers that are relevant to the Court's exercise of
7 its inherent supervisory powers.
8 The documents at issue here were submitted in
9 connection with discovery motions decided by Judge Sweet…
giuffre-maxwell
gov.uscourts.nysd.447706.1294.0
11 pg
…Doe 171 submitted a document
categorized as a letter motion to seal (the “December 5 Motion”)
requesting that the Court (i) seal certain documents that the
1
Case 1:15-cv-07433-LAP Document 1294 Filed 12/11/22…
giuffre-maxwell
gov.uscourts.nysd.447706.1168.0_2
2 pg
…her Reply to 10 pages but rather was
able to conclude in 10 ¾ pages. She respectfully requests that the Court indulge the additional
¾ page in this instance.
Respectfully submitted,
Laura A. Menninger
CC: Counsel of Record via ECF
giuffre-maxwell
gov.uscourts.nysd.447706.1082.0
1 pg
…to other Nonparties.
Ms. Maxwell intends to file the redacted version of the Letter publicly on ECF and seeks
leave only to file the unredacted version and the proposed unredactions under seal.
Respectfully submitted,
Laura A. Menninger
…
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…20-22. Plaintiff agrees, and proposes that Court address all
of the Non-Party Objections submitted and the documents those objections pertain to. Pursuant to
section 2(d) of the Court’s Order and Protocol for Unsealing Decided Motions, sixteen…
giuffre-maxwell
gov.uscourts.nysd.447706.1135.0_6
1 pg
…Ms. Maxwell is submitting any proposed
redactions to the materials to be unsealed tomorrow morning that are in conflict with
Plaintiff’s proposed redactions. These redactions all relate to “descriptions of nonparty
conduct that would allow readers to discern the…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.1
4 pg
…Non-Parties List: Plaintiff Virginia Giuffre and Defendant Ghislaine Maxwell
(collectively, the “Original Parties”) each have submitted under seal a list of non-parties whose
privacy, reputational or other interests may be implicated by the unsealing of the Sealed
Materials…
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