Giuffre v. Maxwell
- Loretta Preska
- 1:15-cv-07433
- U.S. District Court · Southern District of New York
- 3
In Giuffre v. Maxwell, Judge Preska denied intervenors’ motions to partly unseal a list identifying Jane and John Does.
The ruling affected intervenors Julie Brown, Miami Herald Media Company, and Alan Dershowitz, as well as the non-party Jane and John Does whose identifying information and privacy interests were at issue.
What happened
In Giuffre v. Maxwell, intervenors Julie Brown, Miami Herald Media Company, and Alan Dershowitz asked the court to partly unseal a docket filing containing identities associated with Jane and John Does.
Judge Preska said the filing was outdated and would provide little additional public information because related documents and an anonymized list had already been made public. She also found that releasing the filing could threaten the privacy of people whose names remained sealed, including minor victims, health care providers, law-enforcement members, and bystanders.
Judge Loretta A. Preska denied the letter-motions to unseal in part docket entry 1026-3.
The detailed version
- Giuffre v. Maxwell · No. 1:15-cv-07433
- Loretta Preska
- Jan. 5, 2024
Background
Intervenors Julie Brown and Miami Herald Media Company, and intervenor Alan Dershowitz, filed letter-motions seeking to unseal in part docket entry 1026-3. The filing concerned the identities of people identified as Jane and John Does.
Reasons for the Decision
The court gave two reasons for denying the requests. First, docket entry 1026-3 was not an accurate list of non-party names. The parties had since provided the court with an updated list, so disclosing the outdated filing could spread incorrect information.
Second, the court determined that the privacy interests at stake outweighed the presumption that court records should be publicly accessible. The court described the updated filing as similar to a summary exhibit under Federal Rule of Evidence 1006—a document prepared to help the court organize or evaluate information. It included the Does’ names, pseudonyms, home addresses, and the documents in which each person appeared.
The court noted that most of the underlying documents had already been ordered unsealed and that a December 18 order provided an anonymized list of the Does, identified the documents in which they appeared, and explained the court’s decisions about unsealing. In the court’s view, releasing the list would therefore add little information that was not already available. It could also allow people to speculate about the identities of Does whose names remained sealed, even if those names were redacted, because the list was alphabetical. The court emphasized that the group included minor victims, health care providers, law-enforcement members, and bystanders who had not sought publicity.
Disposition
The court held that the same privacy reasons supporting its earlier decisions to deny unsealing continued to outweigh the public’s interest in the filing. Judge Loretta A. Preska therefore denied the letter-motions to unseal in part docket entry 1026-3, identified as docket numbers 1321 and 1323. The opinion states that parties dissatisfied with the reasons for keeping particular Does’ names sealed may appeal to the Court of Appeals.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.