gov.uscourts.nysd.447706.1135.0_6.pdf

Case 1:15-cv-07433-LAP Document 1135 Filed 10/21/20 Page 1 of 1 Haddon, Morgan and Foreman, P.C Laura A. Menninger 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com [email protected] October 21, 2020 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Proposed Redactions to Sealed Materials Related to Non-Parties Giuffre v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: By contemporaneous email to the Court, Ms. Maxwell is submitting any proposed redactions to the materials to be unsealed tomorrow morning that are in conflict with Plaintiff’s proposed redactions. These redactions all relate to “descriptions of nonparty conduct that would allow readers to discern the identity of a given non-party.” Last night at 8:15 p.m., counsel for Ms. Maxwell received Plaintiff’s proposed redactions. Counsel reviewed the proposed redactions to Ms. Maxwell’s 465-page deposition transcript and conferred with Plaintiff’s counsel regarding her proposed redactions during a telephone conference at 1 p.m. today. While undersigned counsel explained the bases for her disagreement and pointed out other areas that should be redacted, Ms. McCawley simply stated that she disagreed without explanation. Counsel for Ms. Maxwell believes that her 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. Epstein’s abuse or as a perpetrator of any such abuse) is disclosed publicly. Respectfully submitted, Laura A. Menninger CC: Counsel of Record via ECF