giuffre-maxwell
gov.uscourts.nysd.447706.811.0
2 pg
…| Case No.: 15-cv-07433-RWS
Dear Judge Sweet:
Movant-Intervenor Michael Cernovich d/b/a Cernovich Media was previously unable to
divine from the publicly available portions of Plaintiff’s Notice of Intent to Request
Redaction (Doc No…
giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…court decision only in a “redacted format,” and
collecting cases); Kemp v. Noeth, 2021 WL 1512712, at *2 (S.D.N.Y. Apr. 15, 2021) (“[F]iling these documents
under seal—rather than redacting the necessary portions—is warranted in…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.1
16 pg
…it should be redacted in the same way as DE
1090-32, but the redactions of the names of Non-Parties whose
time to object has expired should be removed.
Unseal and redact only names and identifying information of
Non…
DataSet-9
EFTA00074964
40 pg
…s deposition. Plaintiff
fails to mention that DE 172's redactions also include purported "summaries" of Doe 162's
deposition and the purported anticipated deposition testimony of Doe 84 (whose name and
testimony the Second Circuit redacted in Brown). Both…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…s deposition. Plaintiff
fails to mention that DE 172’s redactions also include purported “summaries” of Doe 162’s
deposition and the purported anticipated deposition testimony of Doe 84 (whose name and
testimony the Second Circuit redacted in Brown). Both…
DataSet-9
EFTA00173364
5 pg
…We would like to work with you to ensure that those documents are properly redacted
to avoid the devastating harm that would be caused if any of Epstein's victims' names were to be
inadvertently released.
By way of introduction…
DataSet-9
EFTA00174456
5 pg
…We would like to work with you to ensure that those documents are properly redacted
to avoid the devastating harm that would be caused if any of Epstein's victims' names were to be
inadvertently released.
By way of introduction…
DataSet-9
EFTA00175194
5 pg
…We would like to work with you to ensure that those documents are properly redacted
to avoid the devastating harm that would be caused if any of Epstein's victims' names were to be
inadvertently released.
By way of introduction…
DataSet-9
EFTA00173370
3 pg
…We would like to work with you to ensure that those documents are properly redacted
to avoid the devastating harm that would be caused if any of Epstein's victims' names were to be
inadvertently released.
By way of introduction…
DataSet-9
EFTA00174368
5 pg
…We would like to work with you to ensure that those documents are properly redacted
to avoid the devastating harm that would be caused if any of Epstein's victims' names were to be
inadvertently released.
By way of introduction…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…Defendant says that the police report documenting Ms. Giuffre’s rape while a
minor has her name redacted. Of course, such a redaction does Ms. Giuffre little good when
Defendant and her cohorts distribute it to the press - the identity…
giuffre-maxwell
gov.uscourts.nysd.447706.1242.0
9 pg
…prevent the public from speculating as to what material is redacted based on context
clues, but that should not impact the sealing inquiry, which presumes public access. Accordingly,
any redactions should be narrowly tailored and sealing the deposition excerpts in…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…Defendant says that the police report documenting Ms. Giuffre’s rape while a
minor has her name redacted. Of course, such a redaction does Ms. Giuffre little good when
Defendant and her cohorts distribute it to the press - the identity…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.6_1
14 pg
…laws). Here, the defense obtained identity-redacted copies of the police reports and disclosed
them to Plaintiff. Indeed, the Sheriff’s Office completed and provided a form with a list of state
requirements regarding redaction and, consistent with their practice…
giuffre-maxwell
gov.uscourts.nysd.447706.892.0
11 pg
…2016) ; see also March 22 , 2017 Redacted Opinion on
Defendant ' s Motion for Summary Judgment , ECF No. 872 .
2
Case 1:15-cv-07433-RWS Document 892 Filed 05/03/17 Page 3 of 11
At issue is the…
DataSet-9
EFTA00805407
21 pg
…the Miami Herald respectfully requests that the Court unseal all
sealed files on the docket, and remove any redactions from partially redacted documents.
I. THE MIAMI HERALD HAS THE RIGHT TO INTERVENE AS A NEWS
ORGANIZATION
Under the law of…
DataSet-9
EFTA00075024
31 pg
…well.
Plaintiff agrees with Maxwell that everything except for the redaction on page 5 of Docket
Entry 189 should be unsealed. Maxwell Mem. at 12. But because there are no other Non-Parties
mentioned in redacted portions of the document…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…such information
should remain sealed or redacted. See United States v. Sattar, 471 F. Supp. 2d 380, 387 (S.D.N.Y.
2006) (noting that a party’s medical records implicate a privacy interest that would warrant
redaction or sealing)…
giuffre-maxwell
gov.uscourts.nysd.447706.1284.0
17 pg
…criminal
19 trial.
20 About six documents concerning Doe number 28,
21 Ms. Giuffre supports the unsealing except for the redaction of
22 Doe 28's name. Plaintiff takes no position as to approximately
23 26 of the documents.
24 …
giuffre-maxwell
gov.uscourts.nysd.447706.1283.0
17 pg
…criminal
19 trial.
20 About six documents concerning Doe number 28,
21 Ms. Giuffre supports the unsealing except for the redaction of
22 Doe 28's name. Plaintiff takes no position as to approximately
23 26 of the documents.
24 …
Comments