Giuffre_Maxwell_Batch7_p00321.png
Extracted Text (OCR)
Case 1:15-cv-07433-LAP Document 1332-17 Filed 01/08/24 Page 6 of 13
subject of Mr. Epstein and Ms. Groff’s motion], was to be returned to the original
party, parties, non-party, or non-parties who designated it as confidential.
Id. at 7-8 (footnote omitted; quoting Protective Order 4 12).' The Court ordered: “TAJIL
documents, materials, and information subject to the Protective Order must be returned to the
party who designated its confidentiality as of the date this action was dismissed.” /d. at 2
(emphasis supplied).
Notwithstanding the Court’s November 14, 2017, Opinion and our specific requests, the
lawyers for Ms. Giuffre and Doe 43 have refused to comply with Paragraph 12 of the Protective
Order. In the face of the Court’s conclusion that this case “terminat[ed]” on May 25, 2017, the
lawyers have taken the position that this case has not terminated because of the pendency of
appeals of this Court’s orders denying motions to unseal documents filed with the Court and in
the Court’s possession. As these lawyers know the vast bulk of the Confidential Materials was
never filed with the Court. They have offered no reason why they have refused to return or
destroy Confidential Materials “and all copies thereof” in their possession, custody and control
that have not been filed with the Court.
In April 2018 a Miami Herald journalist and the Herald (collectively “the Miami
Herald”) moved to unseal all sealed and redacted documents filed with the Court. Doc.936, at 1.
Messrs. Dershowitz and Cernovich joined the motion. Docs.941 & 947; see Doc.953, at 10. The
lawyers for Ms. Giuffre and Doe 43 took this position on behalf of Ms. Giuffre: “Plaintiff
Virginia Giuffre does not oppose [the Miami Herald’s motion to unseal] to the extent it seeks to
unseal all docket entries . . ., including the unsealing of all trial designated deposition
‘In the footnote the Court acknowledged that the parties could comply with Paragraph 12
by destroying the Confidential Materials, but observed that “without any affidavits provided to
the Court stating [that destruction has occurred], and in light of the present dispute, the Court
infers that such action was not taken.” Jd. at 8 n.1.
Extracted Information
Document Details
| Filename | Giuffre_Maxwell_Batch7_p00321.png |
| File Size | 317.7 KB |
| OCR Confidence | 94.3% |
| Has Readable Text | Yes |
| Text Length | 2,201 characters |
| Indexed | 2026-02-04 12:48:42.042406 |