…Herald", and together with Julie Brown "Intervenors-Appellants") hereby respond in opposition to the redactions proposed by Defendant-Appellee Ghislaine Maxwell and proposed Amicus Curiae John Doe and in support of the limited reactions proposed by Plaintiff-Appellee ARGUMENT I…
…| 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…
…2021 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Limited Motion to Reconsider Proposed Redactions of Ms. Maxwell’s July 2016 Deposition Transcript Giuffre v. Ghislaine Maxwell…
…32 EFTA00090722 VI. THE GOVERNMENT CONCEDES THAT IT WILL NOT OFFER EVIDENCE OF MS. MAXWELL'S ALLEGED FALSE STATEMENTS AND AGREES TO MS. MAXWELL'S PROPOSED REDACTIONS32 VII. THE COURT SHOULD HOLD A PRE-TRIAL EVIDENTI…
…36). In an abundance of caution, and to give the government the chance to review the proposed redactions, we will not file on the public docket any motions containing redactions until we are instructed to do so by the Court…
…Epstein's FOIA request, Mr. Epstein has received just two "batches," the first numbering 372 pages (including redactions) that was produced on December 16, 2014, and the second "batch" numbering 336 pages that was produced 5 12/ months later on…
…Epstein's FOIA request, Mr. Epstein has received just two "batches," the first numbering 372 pages (including redactions) that was produced on December 16, 2014, and the second "batch" numbering 336 pages that was produced 5 12/ months later on…
…2015, Martin Weinberg < wrote: Spoke with FBI Liaison: FBI FOIA finished their review, redactions etc, but it gets sent to a "reviewing" agency that is FBI Southern Fla which has the 2d batch and is reviewing to protect 3d…
…therefore redacted pursuant to paragraph 15 of the Protective Order (Dkt. 36). In order to give the government the chance to review the proposed redactions, we will not file on the public docket any reply memoranda that contain redactions until…
…eHeil95§041Elleeil§f250264%et73i3f 24 explanation of why the document should remain sealed or the redactions should continue specific to that document. I think that's what the Court of Appeals told us we have to do."). Maxwell's general…
…billing records and records of services provided to Mr. Epstein, (id.), would require the redaction of work-product if the government were to be permitted access to them at all, given their irrelevance to the investigation. Since there is no…
…626 F. Supp. 2d at 1237 (concluding that documents must be kept fully sealed because "redactions would be so heavy as to make the released versions incomprehensible and unintelligible"). Filed herewith, under seal in accordance with Rule 6(e), is…
…8). Against this backdrop, we write to offer our assistance in what will no doubt be an extensive and complex redaction process as the various phases of releasing these documents move forward. In our experience of representing Epstein victims for…
…to an in camera hearing wherein this court can make a ruling on relevancy, production, redaction and confidentiality; but only after the Plaintiff shows a compelling need. Furthermore, Epstein's complicated business transactions have no relevancy to this lawsuit and…
…the Court should instead unseal the documents in their entirety, subject only to (1) the “minimal redactions” the Second Circuit applied to the summary judgement record, 1 and (2) redactions of the names of Non-Parties that have submitted Non…
…Cir 1973), cert denied, 415 U.S. 977 (1974). Additionally, any reasonably segregable portion of a responsive record must be provided to me after redactions of any allegedly exempt material, as the law requires. 5 U.S.C. § 552(b…
…s team to redact the report. But it completely misses the point. Judge Walton criticizes Barr not for the redactions made to the Mueller report, but rather for Barr's misleading public comments about it. The Justice Department is silent…
…because Maxwell has filed a motion for summary judgment which could lead to the adjudication of this case. Due to all the redactions in the record, even the reasons for the Protective Order are hidden from the public. (ECF No…
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…mandate, this Court unsealed the summary judgment materials to the public and the press, redacting certain sensitive and private information, including "deposition responses concerning intimate matters where the questions were likely only permitted —and 6 …
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