In the defamation case Virginia Giuffre brought against Ghislaine Maxwell beginning in 2015, Maxwell responded with a motion for summary judgment—arguing that Giuffre’s allegations were not legally defamatory and that Maxwell was entitled to judgment as a matter of law. That motion aimed to avoid a trial by asserting that even if all of Giuffre’s allegations were true, they did not meet the legal threshold for defamation. The motion, along with supporting documents, was filed under seal during pre-trial proceedings. Ultimately, the district court did not grant the motion, and the case was later settled out of court under confidentiality terms in 2017.


When third parties later moved to unseal portions of the sealed record, particularly filings related to the summary judgment motion, the courts determined that these materials were judicial documents subject to a strong presumption of public access. A federal appeals court ordered their partial release because Maxwell had not shown sufficient reasons to overcome the public’s right of access. In other words, although Maxwell sought to dispose of the case quietly and legally via summary judgment—and shield that process from public view—those efforts were rejected, and important portions of the case were ultimately made part of the public record.

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