giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…The Intervenors’ requests to unseal should be denied.
A. Intervenors’ First Proposition of Law: For minor victims of sexual abuse, “redactions
should be applied sparingly to shield only information that would identify those who
have not already been publicly identified…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…Giuffre, including two police reports describing Ms. Giuffre as a
fourteen-year-old victim of rape. Other police reports show her to be the victim of other crimes,
including domestic violence. Defendant should not be allowed to make these police…
giuffre-maxwell
gov.uscourts.nysd.447706.1135.0_6
1 pg
…proposed additional redactions comport
with the Court’s direction that Non-Parties be given the opportunity to review and object
before any information identifying their identity or any conduct attributed to them (including
as either an alleged victim of Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…Giuffre, including two police reports describing Ms. Giuffre as a
fourteen-year-old victim of rape. Other police reports show her to be the victim of other crimes,
including domestic violence. Defendant should not be allowed to make these police…
giuffre-maxwell
gov.uscourts.nysd.447706.1248.0
6 pg
…values.” See Delta Air
Lines, 2020 WL 2614704, at *4.
Intervenors address the Does’ objections based on the categories under which the Does
fall: victims of sexual abuse, on the one hand, and those accused of wrongdoing or who were…
giuffre-maxwell
gov.uscourts.nysd.447706.1087.0
4 pg
…Maxwell contends that Ms. Giuffre’s “proposed
redactions contain errors which reveal the names of [n]onparties,
including alleged victims.” (Id.) Ms. Giuffre suggests in her
response that any unredacted nonparty names may have already been
released by the Court…
giuffre-maxwell
gov.uscourts.nysd.447706.1083.0
3 pg
…produced or answered discovery based on the understanding that
such discovery would be subject to the Protective Order, (b) persons who are identified as
allegedly having engaged in sex acts with Plaintiff or other alleged victims, or facilitated such
acts…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…non-
parties is no longer appropriate. Plaintiff respectfully requests that the Parties be permitted to
review and publish the sealed materials subject to redactions to protect the names and personally
identifiable information of victims only, which would greatly expedite the…
giuffre-maxwell
gov.uscourts.nysd.447706.1329.0
3 pg
…outcome is particularly likely in
the wake of the recent media frenzy about some supposed “Epstein
List” and the mass speculation about the identities of those on
it. The Document includes minor victims, health care providers,
members of law enforcement…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.1
4 pg
…discovery would be subject to the Protective Order previously issued in this action; (b) persons
who are identified as having allegedly engaged in sexual acts with Plaintiff, or other alleged
victims, or allegedly facilitated such acts; (c) persons whose intimate…
giuffre-maxwell
gov.uscourts.nysd.447706.1313.0
1 pg
…and the Miami Herald’s consent to such redactions is based on circumstances
specific to Doe 107 and does not extend to other purported victims living in countries without the
same risks of physical harm.
The Parties therefore respectfully request…
giuffre-maxwell
gov.uscourts.nysd.447706.949.0
31 pg
…names and
16 substituting initials and things like that. They don't
17 identify the names of victims of sexual assaults.
18 But the law is such that we have to decide what
19 standard applies. But in any event…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.1
7 pg
…discovery would be subject to the Protective Order previously issued in this action; (b) persons
who are identified as having allegedly engaged in sexual acts with Plaintiff, or other alleged
victims, or allegedly facilitated such acts; (c) persons whose intimate…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.2
4 pg
…discovery would be subject to the Protective Order previously issued in this action; (b) persons
who are identified as having allegedly engaged in sexual acts with Plaintiff, or other alleged
victims, or allegedly facilitated such acts; (c) persons whose intimate…
giuffre-maxwell
gov.uscourts.nysd.447706.1108.0
5 pg
…discovery would be subject to the Protective Order previously issued in this action; (b) persons
who are identified as having allegedly engaged in sexual acts with Plaintiff, or other alleged
victims, or allegedly facilitated such acts; (c) persons whose intimate…
giuffre-maxwell
gov.uscourts.nysd.447706.1155.0_2
13 pg
…released, could, as she posits, ‘inappropriately influence
potential witnesses or victims.’” Id. at 839. “[U]nder the facts of this case,” the Court held Ms.
Maxwell’s interests connected to her criminal matter are “entitled to little weight.” Id. The…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…Ex. D (GM00780-782).
Plaintiff was not a claimed victim of this crime.
x August 3, 2001 – Plaintiff (then a week shy of her 18th birthday) called police
regarding a theft of cash from her shirt pocket in her apartment…
giuffre-maxwell
gov.uscourts.nysd.447706.1021.0
18 pg
… I
14 would think you would give me this much material. You know,
15 this document implicates this person's privacy interests
16 because she is said to be a victim of sex trafficking. That's
17 all you need…
giuffre-maxwell
gov.uscourts.nysd.447706.1284.0
17 pg
…C.
(212) 805-0300
MBIMGUIC
Case 1:15-cv-07433-LAP Document 1284 Filed 12/02/22 Page 6 of 17 6
1 identity should be sealed because she was a victim of serious
2 abuse by Jeffrey Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1283.0
17 pg
…C.
(212) 805-0300
MBIMGUIC
Case 1:15-cv-07433-LAP Document 1283 Filed 12/02/22 Page 6 of 17 6
1 identity should be sealed because she was a victim of serious
2 abuse by Jeffrey Epstein…
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