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.447706.1084.0
1 pg
…I emailed Ms. Menninger requesting a copy of the unredacted
letter so that we could respond to her objections to our proposed redactions. We have not yet
received those materials so I am not able to comment on them except…
giuffre-maxwell
gov.uscourts.nysd.447706.1086.0
1 pg
…No. 15-cv-7433-LAP
Dear Judge Preska,
As a follow up to my letter from earlier today, we are now in receipt of the unredacted
version of Ms. Menninger’s letter alleging that we made errors in our redactions…
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.447706.461.0
2 pg
…file
Dershowitz' s Reply Declaration with all references to paragraphs 20 and 21 of Mr. Cassell' s
declaration unredacted and not under seal.
Proposed Intervenor Alan M. Dershowitz' s Motion to re-file Dershowitz' s Reply
Declaration with all references…
giuffre-maxwell
gov.uscourts.nysd.447706.1085.0
1 pg
…in her July 30, 2020 letter. DE 1083.
Plaintiff intends to file the redacted version of the letter publicly on ECF and seeks leave only to
file the unredacted version under seal.
Sincerely,
/s/ Sigrid S. McCawley
…
giuffre-maxwell
gov.uscourts.nysd.447706.1075.0
1 pg
…the Court finds that sealing would protect
July 1, 2020 confidential information, Counsel’s request to
file the unredacted reply papers and the exhibits
Honorable Loretta A. Preska thereto under seal is granted. SO ORDERED.
United States District Court
Southern…
giuffre-maxwell
gov.uscourts.nysd.447706.1236.0
1 pg
…Plaintiff has redacted that information pending disposition of the non-party objections.
Plaintiff intends to file the redacted version of the brief publicly on ECF and seeks leave only to
file the unredacted version under seal.
Sincerely,
/s/ Sigrid S…
giuffre-maxwell
gov.uscourts.nysd.447706.550.0
3 pg
…R.
Civ. P. 24(b), and requests that the Court unseal and make public and unredacted Defendant
Ghislaine Maxwell’s Memorandum of Law in Support of Defendant’s Motion for Summary
Judgment (ECF No. 541), Declaration of Laura A. Menninger…
giuffre-maxwell
gov.uscourts.nysd.447706.1311.0
1 pg
…has redacted that information pending disposition of the non-party
objections. Plaintiff intends to file the redacted version of the brief publicly on ECF and seeks
leave only to file the unredacted version under seal.
Sincerely,
/s/ Sigrid S. …
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.447706.1188.0
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.447706.988.0_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.447706.1153.0
1 pg
…Accordingly, Plaintiff intends to file the two documents, which are currently Docket
Entries 204-3 and 212-3, on the docket, with Doe 1’s name unredacted, upon the Court’s
confirmation.
Sincerely,
/s/ Sigrid S. McCawley
…
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.447706.1095.0
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.447706.1168.0_2
2 pg
…s
request that these 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 E under seal.
Ms. Maxwell additionally requests…
giuffre-maxwell
gov.uscourts.nysd.447706.1082.0
1 pg
…York.
Doc. # 62 at 4. The Letter to the Court and the proposed unredactions contain information
deemed CONFIDENTIAL by the parties pursuant to the Protective Order. References to and
discussion of specific CONFIDENTIAL materials are necessary to support Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1072.0
1 pg
…remain under seal.
Ms. Maxwell intends to file the redacted version of the Reply publicly on ECF and seeks
leave only to file the unredacted version and Exhibits A-D under seal.
Respectfully submitted,
Laura A. Menninger
CC: Counsel of…
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