Epstein Files Search

EFTA00029844Set 8

2021-03-093p1,166w

United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Objection to Proposed Redactions of Government's Omnibus Response & Exhibit 5 Dear Judge Nathan: On behalf of defendant Ghislaine Maxwell ... redactions are appropriate to pages 129-134 of the Response. We hereby attach our proposed redactions to pages 129-134, 187-88 and Exhibit 5. The Response and its Exhibits ... Objections to Redactions Proposed on Pages 1-128 The government's proposed redactions on pages 1-128 all relate to materially inaccurate statements made by a prosecutor for the government

https://www.justice.gov/epstein/files/DataSet%208/EFTA00029844.pdf

EFTA00039820Set 9

2021-04-225p1,745w

local rules. You point out that the court has already adopted the government's proposed redactions to Exhibits J and O. The defense is certainly prepared to follow those redactions ... Nathan ordered the parties to docket the April 1, 2021 joint letter or to propose redactions by April 19, 2021. (Dkt. 203). We do not believe any redactions are necessary ... know. Reply Brief 1 The Government takes no position on the defendant's proposed redaction on page 5 of Reply Brief 1. The defense submitted Exhibit A to Reply Brief

https://www.justice.gov/epstein/files/DataSet%209/EFTA00039820.pdf

EFTA00009890Set 8

2021-04-205p1,669w

local rules. You point out that the court has already adopted the government's proposed redactions to Exhibits J and O. The defense is certainly prepared to follow those redactions ... Nathan ordered the parties to docket the April 1, 2021 joint letter or to propose redactions by April 19, 2021. (Dkt. 203). We do not believe any redactions are necessary ... know. Reply Brief 1 The Government takes no position on the defendant's proposed redaction on page 5 of Reply Brief 1. The defense submitted Exhibit A to Reply Brief

https://www.justice.gov/epstein/files/DataSet%208/EFTA00009890.pdf

EFTA00082136Set 9

2021-01-282p546w

providing the Government with an opportunity to respond to the defendant's proposed redactions to its pre-trial motions filed on January 25, 2021. The Government notes at the outset ... necessary as to these particular motions. The Government agrees with the defendant's proposed redactions to the motions for the following reasons: • The proposed redactions to the defendant's motion ... grand jury secrecy . . . is an integral part of our criminal justice system."). • The proposed redactions to the defendant's motion to dismiss Counts One through Four of the Superseding Indictment

https://www.justice.gov/epstein/files/DataSet%209/EFTA00082136.pdf

EFTA00080465Set 9

2021-02-265p1,514w

Document 168 Filed 03/18/21 Page 2 of 5 The proposed redactions mostly satisfy this test. First, the Government's brief in opposition to the Defendant's pre-trial motions ... S.D.N.Y. 2009). As applied to this case, the Court concludes that the proposed redactions in the Government's brief generally serve these interests. Exhibit 1 contains a single redaction ... presumption of access that exists as to that limited portion of the exhibit. The proposed redactions to Exhibit 7 are similar in that they seek to protect from public access

https://www.justice.gov/epstein/files/DataSet%209/EFTA00080465.pdf

EFTA00031598Set 8

2021-02-265p1,518w

Document 168 Filed 03/18/21 Page 2 of 5 The proposed redactions mostly satisfy this test. First, the Government's brief in opposition to the Defendant's pre-trial motions ... S.D.N.Y. 2009). As applied to this case, the Court concludes that the proposed redactions in the Government's brief generally serve these interests. Exhibit 1 contains a single redaction ... presumption of access that exists as to that limited portion of the exhibit. The proposed redactions to Exhibit 7 are similar in that they seek to protect from public access

https://www.justice.gov/epstein/files/DataSet%208/EFTA00031598.pdf

EFTA00088741Set 9

2021-03-222p524w

March 18, 2021 order (the "Order"), the parties have met and conferred regarding proposed redactions to Exhibit 11 and the defendant's cover letter dated March 9, 2021. The parties ... Additionally, the Government wishes to note that some portions of the defense's proposed redactions, which the Court adopted in the Order, would redact language that is contained ... Government respectfully submits under seal the enclosed version of its memorandum of law with proposed redactions consistent the Court's Order, the redactions originally proposed by the Government and contained

https://www.justice.gov/epstein/files/DataSet%209/EFTA00088741.pdf

EFTA00077956Set 9

2021-11-042p267w

Defendant. ALISON J. NATHAN, District Judge: The Court is in receipt of the parties' proposed redactions to the parties' motions in limine, responses in opposition, replies in support, and related ... exhibits. As the Court indicated at today's conference, some of the parties' proposed redactions are overbroad considering the three-part test articulated by the Second Circuit in Lugosch ... Court's review of the requests, the Court requires the parties to submit the proposed redactions as a single document and with the proposed redactions highlighted. The Defendant's proposed

https://www.justice.gov/epstein/files/DataSet%209/EFTA00077956.pdf

EFTA00095491Set 9

2021-10-293p691w

Joint Letter re: Redactions to MILs Thanks, M. I will send you our proposed redactions shortly. And I will send you text for the joint letter a little later. Also ... Joint Letter re: Redactions to MILs Thanks, Chris. We intend to send you our proposed redactions to your motions soon. You can then add any proposed redactions to your motions ... what we send to you. Can you please send us your proposed redactions to our motions, as well as language for us to include in a joint letter about your

https://www.justice.gov/epstein/files/DataSet%209/EFTA00095491.pdf

EFTA00027160Set 8

2021-04-222p342w

Attachments: 2021-04-23_Goy'Lletter_re_proposed_redactions_to_GM_17(c)_filings.docx; Ex._B_2021.04.05_BSF_Reply_re_Maxwell_Rule_17(c)_Subpoena_- _Prpsd_Redact.._[Goyemment_Proposed_Redactions].pdf; 2021.04.05_BSF_Reply_re_Maxwell_Rule ... Joint_Letter_with_BSF_re_redactiontin_Rule_17_pleadings_[Govemm ent_Proposed_Redactions].pdf; 2021.04.02_Defts_Resp_to_BSF_Lth_Motn_to_Quash_Rule_17_Sub_[Goyernment_Propos ed Redactions ... Defts_Resp_to_BSF_Ltr._Motn_to_Quash_Rule_17_Sub_- Prpid.._[Goyemment_Proposed_Redactions].pdf Attached is a draft letter requesting certain redactions and proposed redactions. Any edits? From:I Sent: Wednesday, April

https://www.justice.gov/epstein/files/DataSet%208/EFTA00027160.pdf

EFTA00023662Set 8

2020-08-243p766w

Court Southern District of New York 40 Foley Square New York, NY 10007 Re: Proposed Redactions to Request to Modify Protective Order (Under Seal) United States v. Ghislaine Maxwell ... August 18, 2020 (Doc. 44), Ms. Maxwell hereby respectfully submits under seal her proposed redactions to her Request to Modify Protective Order ("Request"), filed under seal on August ... Maxwell also has filed her Reply under seal and contemporaneously submits her proposed redactions to that pleading.' Ms. Maxwell has no opposition to keeping under seal, and redacting from

https://www.justice.gov/epstein/files/DataSet%208/EFTA00023662.pdf

EFTA00800210Set 9

2019-03-208p1,634w

Plaintiff-Appellee in her response to this Court's Order to Show Cause. The proposed redactions set forth in Appendix A to her response are sufficient to protect the personal ... noting that "the substance of the emails has been made public"). Ms. Giuffres's proposed redactions accomplish this goal by limiting redactions to, variously, social security numbers, the names ... that many of the summary judgment documents are not "judicial documents" and has otherwise proposed redaction or wholesale sealing of documents without any particularized showing of a compelling privacy interest

https://www.justice.gov/epstein/files/DataSet%209/EFTA00800210.pdf

EFTA00028055Set 8

2020-08-175p1,572w

version into the public docket. The Court's decision to adopt the Government's proposed redactions is guided by the three-part test articulated by the Second Circuit in Lugosch ... States v. Amodeo, 71 F.3d 1044, 1048 (2d Cir.1995) ("Amodeo II")). The Government's proposed redactions satisfy this test. First, the Court finds that the defendant's letter motion ... this ruling, the parties are hereby ORDERED to meet and confer with respect to proposed redactions to the Defendant's reply letter, dated August 24, 2020 and the Defendant

https://www.justice.gov/epstein/files/DataSet%208/EFTA00028055.pdf

EFTA00097198Set 9

2020-08-175p1,575w

version into the public docket. The Court's decision to adopt the Government's proposed redactions is guided by the three-part test articulated by the Second Circuit in Lugosch ... States v. Amodeo, 71 F.3d 1044, 1048 (2d Cir.1995) ("Amodeo II")). The Government's proposed redactions satisfy this test. First, the Court finds that the defendant's letter motion ... this ruling, the parties are hereby ORDERED to meet and confer with respect to proposed redactions to the Defendant's reply letter, dated August 24, 2020 and the Defendant

https://www.justice.gov/epstein/files/DataSet%209/EFTA00097198.pdf

EFTA00026705Set 8

2020-08-175p1,611w

version into the public docket. The Court's decision to adopt the Government's proposed redactions is guided by the three-part test articulated by the Second Circuit in Lugosch ... States v. Amodeo, 71 F.3d 1044, 1048 (2d Cir.1995) ("Amodeo Ii")). The Government's proposed redactions satisfy this test. First, the Court finds that the defendant's letter motion ... this ruling, the parties are hereby ORDERED to meet and confer with respect to proposed redactions to the Defendant's reply letter, dated August 24, 2020 and the Defendant

https://www.justice.gov/epstein/files/DataSet%208/EFTA00026705.pdf

EFTA00101995Set 9

2020-08-175p1,613w

version into the public docket. The Court's decision to adopt the Government's proposed redactions is guided by the three-part test articulated by the Second Circuit in Lugosch ... States v. Amodeo, 71 F.3d 1044, 1048 (2d Cir.1995) ("Amodeo IF)). The Government's proposed redactions satisfy this test. First, the Court finds that the defendant's letter motion ... this ruling, the parties arc hereby ORDERED to meet and confer with respect to proposed redactions to the Defendant's reply letter, dated August 24, 2020 and the Defendant

https://www.justice.gov/epstein/files/DataSet%209/EFTA00101995.pdf

EFTA00794214Set 9

13p2,857w

objections to unsealing of summary judgment materials. DOCKET EXHIBIT OBJECTION OBJECTIONS/ # # PLEADINGS in v. Proposed redactions to Def. Statement of Undisputed 537 Facts: Numbered paragraphs ... Proposed redactions: Numbered paragraphs 11-17, 35, 37- 541 52; Section 6(A) (pp. 40 et seq.); Section 6(E) (pp. 56-68) Document titles redacted consistent with Appellee ... Judge Marra 542-9 MM Not a judicial document, not relied upon by Court Proposed redactions: pp. 1-27 up to III (not addressing any summary judgment issues

https://www.justice.gov/epstein/files/DataSet%209/EFTA00794214.pdf

EFTA00019474Set 8

2021-03-223p736w

same page. Thanks, Chris r Chris, We have confirmed that our proposed redactions to Exhibit 11 and those you circulated to Exhibit 11 are the same. As to your newly ... proposed redactions, we understand that you are requesting that we redact portions of our brief that either quote or generally refer to unredacted portions of your publicly filed opening brief ... believe we agree on the redactions to Exhibit 11. I have attached our proposed redacted version of Exhibit 11. I have checked it against yours and I believe they track

https://www.justice.gov/epstein/files/DataSet%208/EFTA00019474.pdf

EFTA00030069Set 8

2021-03-092p252w

Subject: RE: U.S. v. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Objections to Gov't Proposed Redactions in Omnibus Response Date: Tue, 09 Mar 2021 19:56:11 +0000 Attachments: PROPOSED ... Subject: RE: U.S. v. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Objections to Gov't Proposed Redactions in Omnibus Response Thanks. When you can would you mind sending us our proposed ... Subject: FW: U.S. v. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Objections to Gov't Proposed Redactions in Omnibus Response FYI From: Laura Menninger Sent: Tuesday, March

https://www.justice.gov/epstein/files/DataSet%208/EFTA00030069.pdf

EFTA00023462Set 8

2021-10-304p987w

have confirmed that the government has incorporated all of the defense's proposed redactions within the government's proposed redactions. We do not have any more ... these documents. But for the record, we object to all of the government's proposed redactions. Please send me the next batch when you have them ready. Thanks, Chris From ... them filed. With respect to Exhibits: • We are attaching a proposed redacted version of Government exhibit A. • Only defense exhibits E and G can be filed publicly without redactions

https://www.justice.gov/epstein/files/DataSet%208/EFTA00023462.pdf