📄 Extracted Text (3,844 words)
Case 1:15-cv-07433-LAP Document 1156-1 Filed 11/19/20 Page 1 of 16
Exhibit A
Plaintiff’s Position on Docket Entries 231, 279, 315, 320, & 335
Docket Entry1 Plaintiff’s Position
231: Defendant’s Motion for
Rule 37(b) & (c) for Failure to Unseal and redact only (1) medical information and (2) names and
Comply with Court Order identifying information of Non-Parties who have objected to
and Sanctions for Failure to unsealing or whose time to object to unsealing has not yet expired.
Comply with Rule 26(a)
Unseal and redact only names and identifying information of
232 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal and redact only (1) medical information and (2) names and
identifying information of Non-Parties who have objected to
unsealing or whose time to object to unsealing has not yet expired.
232-7 Note: The full version of this deposition transcript was unsealed
by this Court on July 30, 2020, DE 1090-32. If this excerpt of the
transcript is unsealed, 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-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
232-8
Note: The Original Parties sent the Non-Party deponent (Doe 131)
notice of unsealing, and the Non-Party deponent did not request
excerpts.
232-9 Keep sealed (medical records).
232-10 Keep sealed (medical records).
Unseal.
232-11
Note: Original Parties agree.
Unseal and redact only (1) medical information and (2) names and
257 identifying information of Non-Parties who have objected to
unsealing or whose time to object to unsealing has not yet expired.
1
Plaintiff has omitted documents that are not currently sealed or redacted from this chart
1
Case 1:15-cv-07433-LAP Document 1156-1 Filed 11/19/20 Page 2 of 16
Exhibit A
Plaintiff’s Position on Docket Entries 231, 279, 315, 320, & 335
Unseal and redact only names and identifying information of
258 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Keep sealed until Non-Party deponent (Doe 151) time to object
expires.
258-1
Note: Original Parties agree to keep sealed, but for different
reasons.
Keep sealed until Non-Party deponent (Doe 160) time to object
expires.
258-2
Note: Original Parties agree to keep sealed, but for different
reasons.
Unseal and redact only names and identifying information of
Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
258-3
Note: The Original Parties sent the Non-Party deponent (Doe 83)
notice of unsealing, and the Non-Party deponent did not request
excerpts.
Unseal and redact only names and identifying information of
Non-Parties who have objected to unsealing or whose time to
258-4 object to unsealing has not yet expired.
Note: The deponent is not on the Non-Party notification list
because he is a law enforcement officer.
258-5 Unseal but redact medical information and addresses.
258-6 Unseal but redact medical information and addresses.
258-7 Unseal but redact tax returns and addresses.
258-8 Keep sealed (medical records).
Unseal and redact only names and identifying information of
Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
258-9
Note: The Original Parties sent the Non-Party deponent (Doe 67)
notice of unsealing, and the Non-Party deponent did not request
excerpts.
2
Case 1:15-cv-07433-LAP Document 1156-1 Filed 11/19/20 Page 3 of 16
Exhibit A
Plaintiff’s Position on Docket Entries 231, 279, 315, 320, & 335
258-10 Unseal but redact medical information.
Unseal and redact only (1) medical information and (2) names and
261 identifying information of Non-Parties who have objected to
unsealing or whose time to object to unsealing has not yet expired.
269 Unseal but redact medical information.
Unseal.
270
Note: Original Parties agree.
270-1 Keep sealed (medical records).
Unseal and redact only (1) medical information and (2) names and
identifying information of Non-Parties who have objected to
unsealing or whose time to object to unsealing has not yet expired.
270-2 Note: The full version of this deposition transcript was unsealed
by this Court on July 30, 2020, DE 1090-32. If this excerpt of the
transcript is unsealed, 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.
270-3 Unseal but redact address.
Unseal.
270-4
Note: Original Parties agree.
Unseal.
270-6
Note: Original Parties agree.
Unseal.
272
Note: Original Parties agree.
3
Case 1:15-cv-07433-LAP Document 1156-1 Filed 11/19/20 Page 4 of 16
Exhibit A
Plaintiff’s Position on Docket Entries 231, 279, 315, 320, & 335
Unseal and redact only (1) medical information and (2) names and
272-1 identifying information of Non-Parties who have objected to
unsealing or whose time to object to unsealing has not yet expired.
Unseal.
272-2
Note: Original Parties agree.
272-3 Keep sealed (medical records).
272-4 Unseal but redact medical information.
272-5 Already publicly filed (DE 45).
272-6 Already publicly filed (DE 31).
Unseal but redact (1) information about Plaintiff when a minor
272-7
and (2) medical information.
272-8 Keep sealed (medical records)
Unseal.
272-9
Note: Original Parties agree.
Unseal and redact only (1) medical information and (2) names and
identifying information of Non-Parties who have objected to
unsealing or whose time to object to unsealing has not yet expired.
272-10 Note: The full version of this deposition transcript was unsealed
by this Court on July 30, 2020, DE 1090-32. If this excerpt of the
transcript is unsealed, 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.
303 Unseal but redact medical information.
4
Case 1:15-cv-07433-LAP Document 1156-1 Filed 11/19/20 Page 5 of 16
Exhibit A
Plaintiff’s Position on Docket Entries 231, 279, 315, 320, & 335
Unseal.
304
Note: Original Parties agree.
304-1 Unseal but redact medical information.
304-2 Keep sealed (medical records).
304-3 Keep sealed (medical records).
304-4 Unseal but redact medical information.
313-1 Unseal but redact medical information.
279: Plaintiff’s Motion for
Unseal in full.
Adverse Inference Instruction
280 Unseal in full.
Unseal and redact only names and identifying information of
280-1 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal subject to Second Circuit redactions.
280-2 Note: This document was released by the Second Circuit with
redactions. The redactions should match the Second Circuit
redactions.
288-1 Unseal in full.
5
Case 1:15-cv-07433-LAP Document 1156-1 Filed 11/19/20 Page 6 of 16
Exhibit A
Plaintiff’s Position on Docket Entries 231, 279, 315, 320, & 335
288-2 Unseal in full.
290 Unseal in full.
Unseal in full.
291-1
291-2 Unseal in full.
Unseal and redact only names and identifying information of
291-3 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal and redact only names and identifying information of
338 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal and redact only names and identifying information of
338-1 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
338-2 Unseal in full.
Unseal and redact only names and identifying information of
338-3 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal and redact only names and identifying information of
338-4 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal in full.
338-5 Note: These pages of this deposition transcript were released by
the Second Circuit without redactions.
Unseal and redact only names and identifying information of
338-6 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
6
Case 1:15-cv-07433-LAP Document 1156-1 Filed 11/19/20 Page 7 of 16
Exhibit A
Plaintiff’s Position on Docket Entries 231, 279, 315, 320, & 335
Note: The deponent is not on the Non-Party notification list
because he is a law enforcement officer.
Keep sealed until Non-Party deponent (Doe 160) time to object
expires.
338-7
Note: Original Parties agree to keep sealed, but for different
reasons.
Unseal and redact only names and identifying information of
338-8 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal and redact only names and identifying information of
Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
338-9
Note: The Original Parties sent the Non-Party deponent (Doe 7)
notice of unsealing, and the Non-Party deponent did not request
excerpts.
Unseal.
338-10
Note: Original Parties agree.
Unseal and redact only names and identifying information of
353 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
315: Plaintiff’s Motion to
Unseal and redact only names and identifying information of
Enforce Court Order and
Non-Parties who have objected to unsealing or whose time to
Direct Defendant to Answer
object to unsealing has not yet expired.
Deposition Questions
Unseal and redact only names and identifying information of
316 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Keep sealed until Non-Party deponent (Doe 160) time to object
expires.
316-1
Note: Original Parties agree to keep sealed, but for different
reasons.
Unseal and redact only names and identifying information of
316-2 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
7
Case 1:15-cv-07433-LAP Document 1156-1 Filed 11/19/20 Page 8 of 16
Exhibit A
Plaintiff’s Position on Docket Entries 231, 279, 315, 320, & 335
Note: The Original Parties sent the Non-Party deponent (Doe 67)
notice of unsealing, and the Non-Party deponent did not request
excerpts.
Unseal in full.
316-3 Note: These pages of this deposition transcript were released by
the Second Circuit without redactions.
Unseal in full.
316-4 Note: These pages of this deposition transcript were released by
the Second Circuit without redactions.
Unseal in full.
316-5 Note: These pages of this deposition transcript were released by
the Second Circuit without redactions.
Unseal and redact only names and identifying information of
316-6 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal and redact only names and identifying information of
316-7 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal and redact only (1) names and identifying information of
minors and (2) names and identifying information of Non-Parties
who have objected to unsealing or whose time to object to
316-8 unsealing has not yet expired.
Note: Portions of this document were redacted and released by the
Second Circuit. The redactions of the portions already released
should match the Second Circuit redactions.
Unseal and redact only names and identifying information of
339 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal and redact only names and identifying information of
340 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
8
Case 1:15-cv-07433-LAP Document 1156-1 Filed 11/19/20 Page 9 of 16
Exhibit A
Plaintiff’s Position on Docket Entries 231, 279, 315, 320, & 335
Unseal and redact only names and identifying information of
Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
340-1 Note: The full version of this deposition transcript was unsealed
by this Court on July 30, 2020, DE 1090-32. If this excerpt of the
transcript is unsealed, 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
340-3 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal and redact only names and identifying information of
340-4 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Keep sealed until Non-Party deponent (Doe 160) time to object
expires.
340-5
Note: Original Parties agree to keep sealed, but for different
reasons.
Unseal and redact only names and identifying information of
Non-Parties who have objected to unsealing or whose time to
340-6 object to unsealing has not yet expired.
Note: The deponent is not on the Non-Party notification list
because he is a law enforcement officer.
Unseal and redact only names and identifying information of
Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
340-7 Note: The Original Parties sent the Non-Party deponent (Doe 1)
notice of unsealing, the Non-Party deponent requested excerpts,
and the Non-Party deponent did not object to unsealing within two
weeks of receiving the excerpts.
Unseal and redact only names and identifying information of
340-8 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
9
Case 1:15-cv-07433-LAP Document 1156-1 Filed 11/19/20 Page 10 of 16
Exhibit A
Plaintiff’s Position on Docket Entries 231, 279, 315, 320, & 335
Note: The Original Parties sent the Non-Party deponent (Doe 67)
notice of unsealing, and the Non-Party deponent did not request
excerpts.
Keep sealed until Non-Party deponent (Doe 151) time to object
expires.
340-9
Note: Original Parties agree to keep sealed, but for different
reasons.
Unseal and redact only names and identifying information of
368 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal and redact only names and identifying information of
369 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal and redact only names and identifying information of
Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
369-1 Note: This deposition transcript was unsealed on October 22,
2020, DE 1137-13. This document should be redacted in the same
way as DE 1137-13, 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
369-2 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal and redact only names and identifying information of
369-3 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal and redact only names and identifying information of
Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
369-4
Note: The Original Parties sent the Non-Party deponent (Doe 67)
notice of unsealing, and the Non-Party deponent did not request
excerpts.
10
Case 1:15-cv-07433-LAP Document 1156-1 Filed 11/19/20 Page 11 of 16
Exhibit A
Plaintiff’s Position on Docket Entries 231, 279, 315, 320, & 335
Keep sealed until Non-Party deponent (Doe 160) time to object
expires.
369-5
Note: Original Parties agree to keep sealed, but for different
reasons.
Unseal subject to Second Circuit redactions.
369-6 Note: These pages of this deposition transcript were released by
the Second Circuit without redactions, except for page 59 which
contains redactions of a minor’s name.
Unseal in full.
369-7 Note: These pages of this deposition transcript were released by
the Second Circuit without redactions.
Unseal in full.
369-8 Note: These pages of this deposition transcript were released by
the Second Circuit without redactions.
Unseal in full.
369-9 Note: This document was released by the Second Circuit without
redactions.
369-10 Unseal in full.
Unseal and redact only names and identifying information of
Non-Parties who have objected to unsealing or whose time to
369-11 object to unsealing has not yet expired.
Note: The deponent is not on the Non-Party notification list
because he is a law enforcement officer.
Unseal and redact only names and identifying information of
Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
369-12
Note: The Original Parties sent the Non-Party deponent (Doe 145)
notice of unsealing, and the Non-Party deponent did not request
excerpts.
Unseal and redact only names and identifying information of
369-13 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
11
Case 1:15-cv-07433-LAP Document 1156-1 Filed 11/19/20 Page 12 of 16
Exhibit A
Plaintiff’s Position on Docket Entries 231, 279, 315, 320, & 335
Note: The Original Parties sent the Non-Party deponent (Doe 155)
notice of unsealing, and the Non-Party deponent did not request
excerpts.
Unseal and redact only names and identifying information of
Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
369-14
Note: The Original Parties sent the Non-Party deponent (Doe 99)
notice of unsealing, and the Non-Party deponent did not request
excerpts.
Unseal and redact only names and identifying information of
Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
369-15
Note: The Original Parties sent the Non-Party deponent (Doe 122)
notice of unsealing, and the Non-Party deponent did not request
excerpts.
Unseal and redact only names and identifying information of
Non-Parties who have objected to unsealing or whose time to
369-16 object to unsealing has not yet expired.
Note: Non-Party deponent is deceased.
320: Defendant’s Submission
Regarding “Search Terms”
Unseal and redact only names and identifying information of
And Notice Of Compliance
Non-Parties who have objected to unsealing or whose time to
With Court Order
object to unsealing has not yet expired.
Concerning Forensic
Examination Of Devices
321 Retain redaction of email address.
Unseal and redact only names and identifying information of
321-1 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal and redact only names and identifying information of
321-2 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
12
Case 1:15-cv-07433-LAP Document 1156-1 Filed 11/19/20 Page 13 of 16
Exhibit A
Plaintiff’s Position on Docket Entries 231, 279, 315, 320, & 335
Unseal and redact only names and identifying information of
321-3 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal and redact only names and identifying information of
321-4 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal and redact only names and identifying information of
321-5 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal and redact only names and identifying information of
321-6 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal and redact only names and identifying information of
323 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
335: Plaintiff's Motion for
Protective Order for Court to
Direct Defendant to Disclose Unseal but redact information about events when Plaintiff was
Individuals Whom Defendant minor child.
Disseminated Confidential
Information
Unseal.
336
Note: Original Parties agree.
Unseal.
336-1
Note: Original Parties agree.
Unseal but redact information about events when Plaintiff was
336-2
minor child.
Unseal.
336-3
Note: Original Parties agree.
Unseal but redact information about events when Plaintiff was
380
minor child.
13
Case 1:15-cv-07433-LAP Document 1156-1 Filed 11/19/20 Page 14 of 16
Exhibit A
Plaintiff’s Position on Docket Entries 231, 279, 315, 320, & 335
Unseal.
381
Note: Original Parties agree.
Keep sealed (information about events when Plaintiff was minor
381-1
child).
Keep sealed (information about events when Plaintiff was minor
381-2
child).
Keep sealed (information about events when Plaintiff was minor
381-3
child).
Unseal redacted version released by Second Circuit.
381-4
Note: Original Parties agree.
Unseal redacted version released by Second Circuit.
381-5
Note: Original Parties agree.
Unseal but redact telephone numbers, email addresses, and
381-6
addresses.
Unseal redacted version released by Second Circuit.
381-7
Note: Original Parties agree.
Unseal and redact only names and identifying information of
381-8 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal but redact information about events when Plaintiff was
392
minor child.
Unseal and redact only names and identifying information of
393 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
14
Case 1:15-cv-07433-LAP Document 1156-1 Filed 11/19/20 Page 15 of 16
Exhibit A
Plaintiff’s Position on Docket Entries 231, 279, 315, 320, & 335
Unseal subject to Second Circuit redactions.
Note: These pages of these deposition transcripts were all released
393-1 by the Second Circuit without redactions, except for page 24 of
the composite exhibit, where the Second Circuit redacted a
minor’s name.
Unseal in full.
393-2 Note: This document was released by the Second Circuit without
redactions.
Unseal and redact only names and identifying information of
393-3 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal and redact only names and identifying information of
393-4 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal and redact only names and identifying information of
400 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal and redact only names and identifying information of
401 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal and redact only names and identifying information of
401-1 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal and redact only names and identifying information of
401-2 Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
Unseal in full.
401-3 Note: These pages of this deposition transcript were released by
the Second Circuit without redactions.
Keep sealed until Non-Party deponent (Doe 160) time to object
expires
401-4
Note: Original Parties agree to keep sealed, but for different
reasons.
15
Case 1:15-cv-07433-LAP Document 1156-1 Filed 11/19/20 Page 16 of 16
Exhibit A
Plaintiff’s Position on Docket Entries 231, 279, 315, 320, & 335
Unseal and redact only names and identifying information of
Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
401-5 Note: The Original Parties sent the Non-Party deponent (Doe 1)
notice of unsealing, the Non-Party deponent requested excerpts,
and the Non-Party deponent did not object to unsealing within two
weeks of receiving the excerpts.
Unseal and redact only names and identifying information of
Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
401-6
Note: The Original Parties sent the Non-Party deponent (Doe 67)
notice of unsealing, and the Non-Party deponent did not request
excerpts.
16
ℹ️ Document Details
SHA-256
e50a58ab61a60a2033c6d9931bb0cdb27d4fb9a495364dc47fb0375c259ca591
Bates Number
gov.uscourts.nysd.447706.1156.1
Dataset
giuffre-maxwell
Document Type
document
Pages
16
Comments 0