giuffre-maxwell
gov.uscourts.nysd.447706.1285.0
6 pg
…any details about her ordeals two decades
ago, she unquestionably continues to experience trauma similar to that of at least one
other Non-Party Doe whose privacy and identity this Court protected with Plaintiff
Virginia Guiffre’s consent. See Doc…
giuffre-maxwell
gov.uscourts.nysd.447706.1286.0
6 pg
…any details about her ordeals two decades
ago, she unquestionably continues to experience trauma similar to that of at least one
other Non-Party Doe whose privacy and identity this Court protected with Plaintiff
Virginia Guiffre’s consent. See Doc…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…any identifying information, for example, their Social Security
21 number or an address be able to be protected for those that are
22 coming to testify. I know that makes it a little bit more
23 difficult, but if we…
giuffre-maxwell
gov.uscourts.nysd.447706.46.0
22 pg
… Defendant’s Communication with Attorneys Philip Barden, Mark Cohen, and Brett
Jaffe Are Protected by the Attorney-Client Communication Privilege (Entries 1, 2, 9
and 17) ………………………………………
giuffre-maxwell
gov.uscourts.nysd.447706.139.0
7 pg
…pursuant to the Court’s Order [DE 134] dated May 2, 2016.1
ARGUMENT
Statements made by witnesses to law enforcement are protected by the public interest
privilege, which “exists to encourage witnesses to come forward and provide information in…
giuffre-maxwell
gov.uscourts.nysd.447706.148.0
9 pg
…publicly disclosed volumes of information related to her
allegations, to claim that letters or emails from her lawyers or other documents sent to any law
enforcement agency are protected by any privilege. Plaintiff lacks standing to raise the issue and
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…those events is protected from disclosure by law. Florida
statutes protect “[a]ny information in a videotaped statement of a minor who is alleged to be or
who is a victim of sexual battery . . . which reveals that minor’s identity.”…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.1_1
13 pg
…Many of them also concern minors and a victim of sexual assault; therefore, they are
protected by various state statutes. Ms. Giuffre requests that this Court maintain the confidentiality
designations over these police reports and direct the Defendant to disclose…
giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
… Intervenors’ First Proposition of Law: For minor victims of sexual abuse, “redactions
should be applied sparingly to shield only information that would identify those who
have not already been publicly identified.” DE 1248, at 2.
The Reality: Courts routinely seal…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.17
25 pg
…Court or any Orders of the Court.
3. Ms. Maxwell objects to the Requests to the extent they seek documents or
information protected by the attorney/client privilege, the work-product doctrine, Rule 408 of the
Federal Rules of Evidence…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.4_1
4 pg
…I have several.
First, Florida statutes protect "[a]ny information in a videotaped statement of a minor
who is alleged to be or who is a victim of sexual battery ... which reveals that minor' s identity."
Fla. Stat.§ 119.071…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.18
50 pg
…This
Court’s Order ............................................................................................23
5. Information About Ms. Giuffre’s Sexual Abuse is Protected by
Florida Statutes ..................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1122.0_2
13 pg
…on the subject matter in question.
The second circumstance establishing a compelling need for the USVI to gain access
through modification of the Protective Order is that even the identity of the deponent witnesses is
not known or otherwise knowable…
giuffre-maxwell
1320-17
25 pg
…Court or any Orders of the Court.
3. Ms. Maxwell objects to the Requests to the extent they seek documents or
information protected by the attorney/client privilege, the work-product doctrine, Rule 408 of the
Federal Rules of Evidence…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…Law ................................................................ 7
B. All of the Information Sought by the Subpoena Is, At a Minimum,
Protected by the Qualified Privilege Under the Shield Law ....................... 9
1. The Info…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…that it seeks information protected by the attorney client and work product
privileges. Ms. Giuffre objects to this interrogatory in that it is not limited in time or to the
subject nature of this litigation.
8. Identify the individuals referenced…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…that
Giuffre has already produced an unredacted copy of the manuscript to Dershowitz in this case. So
if Dershowitz is correct about Doe’s identity, it is not at all clear what Doe is hoping to accomplish
through continuing to…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…Statutes
Plaintiff also cites Colorado statutes which, she claims, support the proposition that her
identity as the victim of domestic violence is protected by Colorado law. It is not. Section 13-
90-107(k),3 is a testimonial privilege statute…
giuffre-maxwell
gov.uscourts.nysd.447706.1312.0
9 pg
…review of
each document and to: (1) evaluate the weight of the presumption of public access to the materials;
(2) identify and evaluate the weight of any countervailing interests; and (3) determine whether the
countervailing interests rebut the presumption.” Jan…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…that it seeks information protected by the attorney client and work product
privileges. Ms. Giuffre objects to this interrogatory in that it is not limited in time or to the
subject nature of this litigation.
8. Identify the individuals referenced…
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