DataSet-9
EFTA00212739
4 pg
…OF AMERICA,
Respondent.
MOTION TO SEAL APPENDIX TO UNITED STATES'
RESPONSE IN OPPOSITION TO PETITIONERS' MOTION TO USE
CORRESPONDENCE TO PROVE VIOLATIONS OF
THE CRIME VICTIMS' RIGHTS ACT
AND TO HAVE THEIR UNREDACTED PLEADINGS UNSEALED
The U…
DataSet-9
EFTA00800875
4 pg
…individually,
Defendants.
UNOPPOSED EMERGENCY MOTION BYME..M., AND JANE DOE TQ
TEMPORARILY SEAL EPSTEIN'S NOTICE OF UNREDACTED MATERIALS
Sexual assault victims M., and "Jane Doe" (hereinafter "the three victims"),
proceeding pseudonymously and through undersigne…
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.447706.988.1
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…
DataSet-9
EFTA00221711
7 pg
…No.
5, in redacted form. An unredacted copy of the responses will be provided to the court upon the
court's request and/or in camera. In particular, the response to interrogatory number 5 states that
Jane Doe numbers 2…
DataSet-9
EFTA00212713
2 pg
…the matter.
The U.S. Attorney's Office has no independent objection to the filing of "an unsealed, unredacted
pleading reciting the U.S. Attorney's correspondence." In stating that the U.S. Attorney's Office has no
independent objections…
DataSet-9
EFTA00207876
3 pg
…the matter.
The U.S. Attorney's Office has no independent objection to the filing of "an unsealed, unredacted
pleading reciting the U.S. Attorney's correspondence." In stating that the U.S. Attorney's Office has no
independent objections…
DataSet-9
EFTA00207921
2 pg
…suppressing such highly relevant information.
4. You still have not given us your position on the victims' motion to file an unsealed, unredacted pleading
reciting the U.S. Attorney's correspondence. What is your position on that motion: We have…
DataSet-9
EFTA00105300
2 pg
…restriction on disclosure to be permanent.
EFTA00105300
I note also that, if we receive a court order (including a court-ordered subpoena) for the unredacted file, we will notify
you so that you can seek to …
DataSet-9
EFTA00235111
2 pg
…such highly relevant
information.
4. You still have not given us your position on the victims' motion to file an unsealed, unredacted pleading
reciting the U.S. Attorney's correspondence. What is your position on that motion: We have been
…
DataSet-9
EFTA00103619
2 pg
…in the attached cover letter (to be filed via ECF)
and pursuant to Rule 2(B) of the Court's individual rules,
attached for the Court and government is an unredacted version
of the Reply Memorandum In Support of Ms…
DataSet-9
EFTA00207958
2 pg
…suppressing such highly relevant information.
4. You still have not given us your position on the victims' motion to file an unsealed, unredacted pleading
reciting the U.S. Attorney's correspondence. What is your position on that motion: We have…
DataSet-9
EFTA00209799
2 pg
…Brad:
> Good morning. I am writing to ask if you have any objection to a motion for a short extension of time to
comply with Judge Marra's order requiring us to file unredacted pleadings. Some of those have…
DataSet-9
EFTA00091633
3 pg
…Program Statement,
Number I.S. NYM 5500.13, referenced in bates number SDNY 0005392.
13.An unredacted copy of SDNY 7551.
14.An unredacted copy of SDNY 883.
15. SHU Watch Call Logs from August 9, 2019 and August 10…
DataSet-9
EFTA00099413
3 pg
…Program Statement,
Number I.S. NYM 5500.13, referenced in bates number SDNY 0005392.
13.An unredacted copy of SDNY 7551.
14.An unredacted copy of SDNY 883.
15. SHU Watch Call Logs from August 9, 2019 and August 10…
DataSet-9
EFTA00621473
4 pg
…ON
SETTLEMENT AGREEMENT; WORK ON PLAINTIFF'S
MOTION TO GOVERNMENT NOT TO WITHHOLD EVIDENCE; WORK
ON PLAINTIFFS MOTION TO FILE UNREDACTED PLEADINGS. 8.10 11,340.00
JP LEGAL FEES - VARIOUS E-MAILS CONCERNING DOE v USAO
LITIGA…
DataSet-9
EFTA00184099
29 pg
…Supplemental Discovery Request 4. Please provide an unredacted copy of Jane Doe 3's
FBI 302 pertaining to the 2011 interview in Australia of her in connection with sexual abuse by
Jeffrey Epstein.
Supplemental Discovery Request 5. On about November…
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.447706.1123.0
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…