Ghislaine Maxwell Little Black Book Names: Secret No More

The convicted sex trafficker is refusing to protect VIPs, Epstein staffers and others after her disastrous trial, according to new documents.

Ghislaine Maxwell Little Black Book: The anonymous names in the Virginia Giuffre versus Ghislaine Maxwell defamation case papers were today dealt a blow after the convicted sex trafficker withdrew support for keeping their identities sealed.

Both parties today lodged letters to the court in regards to the unsealing, or un-redacting, of various individuals, known as ‘the Does’.

Ms Giufree’s lawyer Sigrid McCawley wrote: ‘Now that Maxwell’s criminal trial has come and gone, there is little reason to retain protection over the vast swaths of information about Epstein and Maxwell’s sex-trafficking operation that were originally filed under seal in this case.’

Non-party does in the case are now facing uncertainty and a wait after Maxwell withdrew any support for keeping their names sealed.

This has been described as the prisoner taking her “bat and ball” and going home after her disastrous criminal trial.

Ghislaine Maxwell Little Black Book

Several of the individuals are objecting and trying to remain a number on the public documents, while others are fine with the unsealing.

Of course, that probably means that those who are fine with being named are most likely to be adult survivors or Jeffrey Epstein staff.

Ghislaine Maxwell Little Black Book
Jeffrey Epstein and Ghislaine Maxwell

Those who don’t wish to be named and, therefore, forever associated with Ghislaine Maxwell and Jeffrey Epstein, may be employees, business partners or close friends.

Already so many names have been typed out in the various documents lodged, but there are several that have been missing, with many believing theses names are behind the black redactions.

In summary:

  • The objecting Does are 17, 73, 93, 151, and 55 and 56.
  • Doe 53 does not oppose unsealing.
  • Doe 54 does not generally oppose unsealing.

Ghislaine Maxwell Little Black Book

From the Maxwell letter lodged, docket 1238:

“Each of the listed Does has counsel who have ably asserted their own respective privacy rights. Ms Maxwell therefore leaves it to this Court to conduct the appropriate review consistent with the Order and Protocol for Unsealing Decided Motions.”

Ghislaine Maxwell Little Black Book
Ghislaine Maxwell & Epstein Coconspirator Sarah Kellen

Now let’s look at the Does. I’ve quickly gone through all the documents and tried to see if there were mishaps, and yes in one case there has been. 

Doe 17 is mentioned in four documents on the list of decided motions before the Court.

From Document 1237, docketed by Virginia Giuffre’s legal team, about Doe 17’s objections: 

That Doe 17 does not want to be associated with Maxwell and Epstein because, as they write, “if [the material] allowed to be made public, [it] will cause [them], to say the least, annoyance and embarrassment.”.

Doe 17 further writes that disclosure of this information will cause them severe anxiety and distress. They do not cite a single legal authority suggesting that these concerns outweigh the presumption of public access. In any event, Doe 17’s objections are not enough to rebut the presumption of public access.

First, three of the documents only mention Doe 17’s name in the context of discovery search terms or a Federal Rule of Civil Procedure Rule 26 disclosure.

Ghislaine Maxwell Little Black Book

The list of search terms that include Doe 17’s name, including no personal or private information about them, and simply list Doe 17’s name among many other.

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Maxwell massaging Epstein’s foot

The person remarks that they have “never been a witness to any conduct relevant to this lawsuit” and that when the accusations against Epstein were publicized in the media, they were “shocked and did not want to have anything to do with him”.

Regardless, Ms Giuffre agreed to redact Doe 17’s address in Docket Entry 423-4, which should alleviate their privacy concerns.

Doe 17’s assertion that unsealing would cause them “extreme personal, physical and reputational harm”, that, in turn, has caused health problems is too generalized to warrant sealing.

Especially given the narrow categories of information the Court has kept sealed thus far: information concerning sexual relations between consenting adults, medical records and certain documents that might have prejudiced Maxwell’s, now concluded, criminal trial.

In any event, any purported privacy concerns raised by Doe 17 are less weighty, given that they remain free to publicly address any allegations made against them. 

Ghislaine Maxwell Little Black Book

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Interestingly Doe 17 (along with 73, 151) is in the 423-4 Declaration of Maxwell lawyer Laura A Menniger in support of motion to compel settlement agreement.

Doe 53 does not oppose unsealing. Doe 53 is mentioned in 36 documents associated with the decided motions. 

Looking through the various documents listed that have been listed as Doe documents, Doe 53 is mentioned in docket 172, Virginia Giuffre’s request to exceed Rule 30 which states the maximum of 10 depositions for a civil case. This document is 28 pages and includes an index of who VG had already deposed and those she wished to examine.

The document states that Ms Giuffre had already deposed;

Ghislaine Maxwell

Johanna Sjoberg

The further depositions included housekeepers Juan Alessi and Maria Alessi

Pilot David Rodgers

Rinaldo Rizzo, the Dubin butler

Jean Luc Brunel (model agent now in a French cell awaiting trial),

Ross Gow (Maxwell PRadvisor),

Dana Burns (friend),

Jo Jo Fontanella (former NY butler for JE),

Detective Joe Recarey (Palm Beach),

Michael Reiter (Former Palm Beach Police Chief ),

Emmy Tayler (enabler),

Alexandra Hall (survivor),

Nadia Marcinkova (pilot and enabler and survivor),

Sarah Kellen Vickers (enabler)

Jeffrey Epstein.

Ghislaine Maxwell Little Black Book

In the body of this document, extrapolating of the various names and what importance their depositions would be, but in the order of the index above, the name Alexandra Hall is redacted, but is clearly in the index.

Number 14 in the body of the document has been redacted. Therefore I’m taking a punt that Doe 53 is a survivor.

172 index
172 index
172 body
172 body

DOE 54 is mentioned in 31 documents associated with decided motions.

From Document 1237, docketed by Virginia Giuffre’s legal team.

Doe 54 does not opposes unsealing any of these documents aside from a single question in Docket 450-1 which they contend was a transcription error.

The Plaintiff does not dispute that there may have been a transcription error, but this does not justify sealing at all, let alone the sealing of the question itself (to which Doe 54 concedes there is no error).

Doc 450 is a declaration filled by Maxwell’s team in support to compel testimony of Jeffrey Epstein. In regards to her identity I believe her to be an adult survivor or someone who worked for either Ghislaine Maxwell or Epstein but not in a role some would categorize as a physical abuser. 

Does 55 and 56

These Does are dealt with together and are mentioned in four excerpts from the same deposition transcript. 

From Document 1237, docketed by Virginia Giuffre’s legal team.

Both Does 55 and 56’s objections are predicated on the notion that the deposition itself is unreliable and that their privacy interests warrant continued sealing. Neither reasons surmount the presumption of public access such to warrant continued sealing. 

Next, apart from questioning the veracity of the deposition testimony, both Does 55 and 56 fail to demonstrate countervailing interests that outweigh the presumption of public access.

Instead both Does conclude that the material would negatively impact their privacy and that unsealing would harm them by associating them with Maxwell and Epstein, regardless of where the underlying conduct surrounding their mention could be proven. 

Further, the names of both Does 55 and 56 have already been the subject of media attention in connection with Epstein and Maxwell, militating the risk of any specific harm resulting from any unwanted attention to the deposition where they are mentioned. 

Further, Does 55 and 56’s argument that they did not have a chance to refute the Deponent’s (person who makes a deposition or affidavit under oath) testimony is unavailing given their continued ability to do so now – there is simply nothing stopping them from responding to the deponent’s testimony if they contend it is false. 

This pair of Does seem to not just be linked together, but seem to have submitted together, possibly indicating some form of relationship.

Ghislaine Maxwell Little Black Book

Ghislaine Maxwell Little Black Book

DOE 73 Doe 73’s name appears in seven documents, in connection with letters discussing search terms.

From Document 1237, docketed by Virginia Giuffre’s legal team.

Doe 73’s objections to unsealing is based on their general aversion to being associated with Maxwell and Epstein, and their claims that they had no knowledge of any of the underlying claims predicating this action. 

Doe 73 (along with 17, 151) is in the 423-4 Declaration of Laura A Menniger in support of motion to compel settlement agreement.

DOE 93 Is mentioned in three deposition excerpts associated with decided motions. 

From Document 1237, docketed by Virginia Giuffre’s legal team.

They write that they have ‘no relevance to the issues in this dispute’ and that “[g]iven the sensitive and potentially salacious issues’ at issue, the materials should remain sealed.

DOE 151

Doe 151 is mentioned in 47 documents attached to the motions. This Doe is throughout the documents from the early documents to those right to the end, including 423-4 one of the documents about a settlement agreement lodged by Ghislaine Maxwell’s legal team. 

From Document 1237, docketed by Virginia Giuffre’s legal team.

At bottom, Doe 151’s objection centres on a) the fact that they testified pursuant to a protective order, b) that they are trying to live a private life and do not want any attention stemming from disclosure, and c) they “will be hounded and pursued by the media for comment and elaboration.” These reasons, yet again, do not justify continued sealing.

For starts Doe 151 and material associated with them has already been widely reported in the media. Indeed some material mentioned in their objections has already been unsealed by the second circuit in 2019 (and not “leaked,” as Doe 151 suggests in their objections).

With respect to their privacy concern, Doe 151’s involvement in the underlying action has already been widely reported.

Indeed, the objection notes that they have declined media inquires in pursuit of their privacy.

Doe 151’s concern of future, and at this point speculative, media attention is unpersuasive, as they have already explained hat they have been subject of media attention, have declined to engage, and will “continue to refuse comment” going forward.

With respect to Doe 151’s health concerns, although Plaintiff would not want to put anyone’s health in jeopardy, much of the information about Doe 151 is already largely public; thus, any privacy concerns cannot defeat the presumption of public access. 

Regardless, Doe 151’s reasons for not engaging with the media are irrelevant to this analysis, and to the extent that they feel unduly limited in their ability to respond, they can seek appropriate recourse. 

So who are these Does? I believe 53 and 54 are survivors or staff.

As I said above I believe 55 and 56 are in some way connected. 

We know there were redacted names in the released depositions that many have said were former President Bill Clinton, Prince Andrew and lawyer Alan Dershowitz.

The information about Doe 151 having health issues may make many people point to Dershowitz due to his recent filing in the case for defamation that Giuffre brought against him where he claimed ill health.

However Dershowitz can be found in the documents, in the subpoena to Jean Luc Brunel, Doc 229-6. Although it may be a missed redaction, as we found so many during past unsealing, particularly in the depositions.

Ghislaine Maxwell Little Black Book

In the subpoena to Jean Luc Brunel, the former model agent, who is now in a jail cell in France, was asked to provide documents:

1: All video tapes, audio tapes, photographs, including film negatives or film slides, CDD’s, or any other print or electronic media taken that relate to:

(1) Alan Dershowitz; (2) Virginia Roberts’ (3) Alan Dershowitz in the presence of Virginia Roberts’ and 4) Alan Dershowitz in the presence of Jeffrey Epstein and and/or any female agent or employee of Jeffrey Epstein.5:

All documents that relate to:

(1) Alan Dershowitz; (2) Virginia Roberts; (3) Alan Dershowitz in the presence of Virginia Roberts; and (4) Alan Dershowitz in the presence of Jeffrey Epstein and /or any female agent or employee of Jeffrey Epstein. 

Other names that are mentioned in this subpoena are Emmy Taylor, Sarah Kellen and Nadia Marcinkova.

Ghislaine Maxwell Little Black Book