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.447706.988.1
5 pg
…doesn’t appear to be on the binder index. Attached is what I found in the unredacted e-mail
distribution for this date.
I believe you should now have everything you need. Please do not hesitate to contact me should…
giuffre-maxwell
gov.uscourts.nysd.447706.988.0_2
6 pg
…doesn’t appear to be on the binder index. Attached is what I found in the unredacted e-mail
distribution for this date.
I believe you should now have everything you need. Please do not hesitate to contact me should…
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.447706.1068.0
31 pg
…answers to “personal”
or “embarrassing” questions. Pages 2 through 8 of Docket Entry 172 should therefore be
unredacted.
If the Court declines to unseal pages 2 through 8 in full, the following items in Docket
Entry 172 summarize portions of…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…testimony unsealed in the Maxwell case. Insofar as Doe is
continuing to oppose Dershowitz’s access to confidential materials from Maxwell in order to
prevent Dershowitz from obtaining an unredacted copy of the manuscript, it should be noted that
Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1154.0_5
3 pg
…Doe 1 and 2
submitted an objection to their names being released, yet Plaintiff now seeks to publicly file
Docket Entries 204-3 and 212-3 with Doe 1’s name unredacted. For the reasons addressed in
Case 1…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…See, e.g., DE 1138 (Prof.
Dershowitz’s request that his name be unredacted). Ms. Maxwell asserted only that knowledge
of who was objecting might aid the Court in “conducting future proceedings.” See DE 1100
(“Although [providing notice to all…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…form, which I have not reviewed, and unredacted form, various
4 bases for why LiButti has not been met here by the plaintiff.
5 But the alternative argument the plaintiff makes,
6 which is this is not ripe for decision…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.35
10 pg
…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 conceded that…
giuffre-maxwell
gov.uscourts.nysd.447706.949.0
31 pg
…seal. They had to publish
6 redacted versions, but they were able to submit unredacted
7 under seal with public redactions, which is why even last night
8 Professor Dershowitz's counsel was still filing something
9 automatically with redactions…
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.447706.263.0
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.19_2
32 pg
…day just before the depositions
of - and Recai·ey, Plaintiff disclosed 623 new documents, including for the first time the
"unredacted" police repo11s from Palm Beach, that Plaintiff cleai·ly has had in her possession, or
her counsel 's possession…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.9
18 pg
…For the Court’s ease of
reference, the Reply Brief is attached hereto in unredacted form as Exhibit M (under seal).
40. Neither the Emails nor the Manuscript were disclosed to me or my lawyers in the
lawsuit between me…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.3_2
12 pg
…ghislaine-maxwell-deposition-gives-insight-into-epstein-relationship-94465093962
27 https://pagesix.com/2020/10/26/alan-dershowitz-seeks-to-unredact-name-in-ghislaine-maxwell-deposition/
28 https://www.reuters.com/article/people-ghislaine-maxwell/ghislaine-maxwell-repeatedly-denies-witnessing…
giuffre-maxwell
gov.uscourts.nysd.447706.1204.0
3 pg
…Ms. Maxwell will file a
redacted version of the letter on ECF, and she requests leave to file the unredacted version of
this letter under seal with this Court.
Respectfully submitted,
Laura A. Menninger
CC: Counsel of Record via ECF
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