giuffre-maxwell
gov.uscourts.nysd.447706.1258.0
3 pg
…and requests that the Court unseal and make
public and unredacted any and all documents that identify the men who abused the girls trafficked
by Jeffrey Epstein and Defendant Maxwell (“the Epstein Client List”).
Sealing those documents violates the rights…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.38
8 pg
…NO. CACE 15-000072
PAUL G. CASSELL,
Plaintiffs,
v.
ALAN DERSHOWITZ,
Defendant.
SEALED, UNREDACTED SUPPLEMENTAL MOTION TO STRIKE AND FOR
SANCTIONS
Non-Party Virginia Giuffre, by and through undersigned counsel, hereby moves for this
Court to enter sanctions against Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.1215.0
13 pg
…get her story straight.
In her Response in Opposition to Motion to Intervene, DE 406, plaintiff fought
strenuously to preclude Professor Dershowitz’s access to unredacted discovery motions and the
attachments thereto. Her reasons were many and varied. She contended…
giuffre-maxwell
gov.uscourts.nysd.447706.1188.0
3 pg
…93, and
151 should be unredacted in those documents and whether the names of other nonparties who have
not objected should be unredacted in those documents.
Accordingly, Plaintiff proposes next addressing the following list of motions that mention
Does 55…
giuffre-maxwell
gov.uscourts.nysd.447706.1095.0
2 pg
…for a stay pending appeal. She also
requests leave to file under seal the unredacted copy of Exhibit 7 to her stay motion.
It is hereby ORDERED that the motion for a stay pending appeal is GRANTED. The stay will
…
giuffre-maxwell
gov.uscourts.nysd.447706.1087.0
4 pg
…onparties,
including alleged victims.” (Id.) Ms. Giuffre suggests in her
response that any unredacted nonparty names may have already been
released by the Court of Appeals, but otherwise acknowledges that
it is possible there were errors in her proposed redactions…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.23
10 pg
…about Plaintiff’s claim of
victimhood.
Furthermore, Plaintiff left unredacted her assertion that it is “undisputed” that Ms.
Roberts was the child victim of sexual abuse, leaving the mis-impression with the public that Ms.
Maxwell has in some way…
giuffre-maxwell
gov.uscourts.nysd.447706.1123.0
2 pg
…party “may file an
opposition stating the reasons why any Sealed Item should be unsealed” (¶ 2(d)) and “any
Original Party may file its own objection to unsealing/unredacting” (¶ 2(e)).
Case 1:15-cv-07433-LAP Document 1123…
giuffre-maxwell
gov.uscourts.nysd.447706.1052.0
4 pg
…list. And each time the Court makes a ruling, it
would be ruling only on whether the names of two Does should be unsealed or unredacted in a
particular set of documents. That is inconsistent with Paragraph 2(j). And…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.1
8 pg
…granted Ms. Giuffre’s Motion to Compel Defendant to Answer
Deposition Questions in its June 20, 2016, Order. See June 20, 2016, Unredacted Order, at p. 9-
10. This deposition is currently scheduled for July 22, 2016. Ms. Giuffre is…
giuffre-maxwell
gov.uscourts.nysd.447706.1157.0_1
5 pg
…Letter at 1.)
Defendant argues that “Doe 1 and 2 submitted an objection to
their names being released” and thus Docket Entries 204-3 and
212-3 should not be filed publicly with Doe 1’s name unredacted.
(See Def…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.0
35 pg
…brief), the Second Circuit did not redact the entire testimony.
ECF No. 1150-2. For example, the Second Circuit left the following unredacted:
“Was Virginia, in the period of around 2000, the youngest person that, as you
understood it…
giuffre-maxwell
gov.uscourts.nysd.447706.1029.0
2 pg
…agent on the list. Ross Gow is a media specialist who issued the
key defamatory statement that was the subject of this litigation on behalf of Defendant.1 His
unredacted name also appears in numerous unsealed documents, including Plaintiff’s…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…though, that those redactions are possible to crack. That’s because the
deposition—which you can read in full here—includes a complete alphabetized index of the
redacted and unredacted words that appear in the document. For example, after cracking…
giuffre-maxwell
gov.uscourts.nysd.447706.363.13
15 pg
…As set forth in Churcher’s opening brief, Maxwell cannot make the “clear showing”
necessary to overcome the Shield Law protections for non-confidential newsgathering material.
The unredacted Response does not alter this conclusion. Maxwell argues that “[t]he information…
giuffre-maxwell
gov.uscourts.nysd.447706.63.0
22 pg
…first set forth, and that pleading preceded by three days
Ms. Maxwell’s denial of Plaintiff’s allegations. Yet Plaintiff has not even produced an
unredacted copy of the pleading setting forth her allegations about Ms. Maxwell. Instead, she
produced…
giuffre-maxwell
gov.uscourts.nysd.447706.1100.0
16 pg
…the last round of
unsealings, we request that the Protocol be amended to require the Responding Original Party
who proposes unsealing to supply with their Response a proposed unredacted set of the
pleadings at issue, for the Court’s consideration…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.13
15 pg
…As set forth in Churcher’s opening brief, Maxwell cannot make the “clear showing”
necessary to overcome the Shield Law protections for non-confidential newsgathering material.
The unredacted Response does not alter this conclusion. Maxwell argues that “[t]he information…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.8
29 pg
…Plaintiff
cannot establish). Plaintiff’s RFP and motion presuppose that the only way Mr. Pagliuca could
have known Plaintiff’s previous false accusations of sexual assault is by reviewing unredacted
2
copies of the police reports, hence, the RFP’s…
giuffre-maxwell
gov.uscourts.nysd.447706.263.0
14 pg
…As set forth in Churcher’s opening brief, Maxwell cannot make the “clear showing”
necessary to overcome the Shield Law protections for non-confidential newsgathering material.
The unredacted Response does not alter this conclusion. Maxwell argues that “[t]he information…
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