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Extraction Summary
5
People
4
Organizations
2
Locations
2
Events
1
Relationships
4
Quotes
Document Information
Type:
Court filing (legal memorandum/motion regarding sealing of exhibits)
File Size:
697 KB
Summary
This document is page 17 of 54 from a court filing (Document 380) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on October 29, 2021. It argues for the sealing of exhibits containing the names or last names of specific minor victims (Minor Victim-1, 3, 4, 6) and Witness-1 to prevent harassment and protect privacy, citing various legal precedents. A footnote also argues that courtroom sketch artists should be precluded from drawing the faces of victims.
People (5)
| Name | Role | Context |
|---|---|---|
| Minor Victim-1 | Victim/Witness |
Subject of request to seal exhibits containing their name.
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| Minor Victim-3 | Victim/Witness |
Subject of request to seal exhibits containing their name.
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| Witness-1 | Witness |
Subject of request to seal exhibits containing their name.
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| Minor Victim-4 | Victim/Witness |
Subject of request to seal exhibits containing their last name.
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| Minor Victim-6 | Victim/Witness |
Subject of request to seal exhibits containing their last name.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| United States District Court (S.D.N.Y.) |
Jurisdiction cited in case law (United States v. Cohen).
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| Second Circuit Court of Appeals (2d Cir.) |
Cited in legal precedents (Amodeo, Graham).
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| Department of Justice (DOJ) |
Indicated by footer code DOJ-OGR.
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| Warner Commc'ns, Inc. |
Cited in case precedent Nixon v. Warner Commc'ns.
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Locations (2)
| Location | Context |
|---|---|
|
Court district mentioned in citations.
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Court district mentioned in footnote citation (Raniere).
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Relationships (1)
The Government
→
Legal Protection
→
Minor Victims
The Government is filing a motion to seal exhibits to protect the victims' identities.
Key Quotes (4)
"The sealing of exhibits containing the names of Minor Victim-1, Minor Victim-3, and Witness-1, or the last names of Minor Victim-4 and Minor Victim-6, is also appropriate."Source
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Quote #1
"The Government’s sealing request is narrowly tailored to prevent public disclosure only of those exhibits which would identify by name the Minor Victims testifying in this case."Source
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Quote #2
"Any other result would defeat the purpose of permitting the Minor Victims to testify using pseudonyms or their first names, incurring all the harms described above."Source
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Quote #3
"For the same reasons, any courtroom sketch artists should be precluded from drawing the faces of victims."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,143 characters)
Case 1:20-cr-00330-PAE Document 380 Filed 10/29/21 Page 17 of 54
disclosure of such information will identify the Minor Victims with particularity, and thus
subject them to harassment, retaliation, and embarrassment, or additional consequences.7
subject them to harassment, retaliation, and embarrassment, or additional consequences.7
The sealing of exhibits containing the names of Minor Victim-1, Minor Victim-3, and
Witness-1, or the last names of Minor Victim-4 and Minor Victim-6, is also appropriate.
Although "the public has an 'especially strong' right of access to evidence introduced in trials,"
United States v. Amodeo, 71 F.3d 1044, 1049 (2d Cir. 1995), it "is not absolute," Nixon v.
Warner Commc'ns, Inc., 435 U.S. 589, 598 (1978); see also United States v. Graham, 257 F.3d
143, 149 (2d Cir. 2001). For example, "subject matter [that] is traditionally considered private
rather than public" will weigh "heavily against access." Amodeo, 71 F.3d at 1050. This includes
certain "financial records . . . , family affairs, illnesses, embarrassing conduct with no public
ramifications, and similar matters . . . ." Id. at 1051. "[T]he 'venerable' privacy-interest
exception to the presumption of access exists to avert 'cater[ing] 'to a morbid craving for that
which is sensational and impure.'" United States v. Cohen, 366 F. Supp. 3d 612, 626-627
(S.D.N.Y. 2019) (quoting Amodeo, 71 F.3d at 1051). The Government's sealing request is
narrowly tailored to prevent public disclosure only of those exhibits which would identify by
name the Minor Victims testifying in this case. Any other result would defeat the purpose of
permitting the Minor Victims to testify using pseudonyms or their first names, incurring all the
harms described above. See Paris, 2007 WL 1484974, at *2 (concluding that the interest in
Witness-1, or the last names of Minor Victim-4 and Minor Victim-6, is also appropriate.
Although "the public has an 'especially strong' right of access to evidence introduced in trials,"
United States v. Amodeo, 71 F.3d 1044, 1049 (2d Cir. 1995), it "is not absolute," Nixon v.
Warner Commc'ns, Inc., 435 U.S. 589, 598 (1978); see also United States v. Graham, 257 F.3d
143, 149 (2d Cir. 2001). For example, "subject matter [that] is traditionally considered private
rather than public" will weigh "heavily against access." Amodeo, 71 F.3d at 1050. This includes
certain "financial records . . . , family affairs, illnesses, embarrassing conduct with no public
ramifications, and similar matters . . . ." Id. at 1051. "[T]he 'venerable' privacy-interest
exception to the presumption of access exists to avert 'cater[ing] 'to a morbid craving for that
which is sensational and impure.'" United States v. Cohen, 366 F. Supp. 3d 612, 626-627
(S.D.N.Y. 2019) (quoting Amodeo, 71 F.3d at 1051). The Government's sealing request is
narrowly tailored to prevent public disclosure only of those exhibits which would identify by
name the Minor Victims testifying in this case. Any other result would defeat the purpose of
permitting the Minor Victims to testify using pseudonyms or their first names, incurring all the
harms described above. See Paris, 2007 WL 1484974, at *2 (concluding that the interest in
______________________________________________________________________________
7 For the same reasons, any courtroom sketch artists should be precluded from drawing the faces
of victims. See May 6, 2019 Text Order, Raniere, 18 Cr. 204 (NGG) (E.D.N.Y.) ("Sketch artists
. . . may not draw exact likenesses of jurors or witnesses other than co-defendants should they
testify . . . .").
7 For the same reasons, any courtroom sketch artists should be precluded from drawing the faces
of victims. See May 6, 2019 Text Order, Raniere, 18 Cr. 204 (NGG) (E.D.N.Y.) ("Sketch artists
. . . may not draw exact likenesses of jurors or witnesses other than co-defendants should they
testify . . . .").
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