giuffre-maxwell
gov.uscourts.nysd.447706.1154.0_5
3 pg
…Plaintiff asserts her
belief that the Court will consider in this current round of unsealing not only whether to
release Doe 1 and 2’s names and identifying information but also the same information for
any Non-Party “whose deadlines…
giuffre-maxwell
gov.uscourts.nysd.447706.1185.0_1
1 pg
…Specifically, Mr. Doe asserts that the Protective
Order permits the parties in Giuffre v. Dershowitz to file sealed material from Giuffre v. Maxwell to the
public docket in Dershowitz without prior judicial approval.
Professor Dershowitz reiterates and incorporates by reference…
giuffre-maxwell
gov.uscourts.nysd.447706.87.0
4 pg
…moves for a brief adjournment of the April 13 hearing until April 21, 2016, when Ms.
Maxwell’s Motion to Compel will be heard by this Court. As grounds she asserts as
follows:
1. On April 5, 2016, Paul A…
giuffre-maxwell
gov.uscourts.nysd.447706.116.0
6 pg
…Appear Pro Hac
Vice in this Matter (Doc. #112 - 115). As further grounds, she asserts as follows:
INTRODUCTION
On April 21, 2016, the Court conducted a hearing on the Motions of Messrs. Cassell and
Edwards to appear pro hac vice…
giuffre-maxwell
gov.uscourts.nysd.447706.155.0
15 pg
…for Court intervention. The parties have been
unable to reach resolution on these issues.
INTRODUCTION
Plaintiff asserts improper claims of attorney-client and work product privilege in her
privilege log and wrongfully withheld documents based on these unsubstantiated claims. See
…
giuffre-maxwell
gov.uscourts.nysd.447706.1119.0_3
4 pg
…untethered to the facts of this case, and it points to no shortcoming
regarding the already unsealed summary judgment materials. It merely asserts, in conclusory
fashion, that the requested materials “are judicial documents” and that no countervailing interests
justify continued…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…this case is the most expeditious manner in which to pursue their rights. Because
the background regarding their abuse is relevant to the Court’s assessment of whether to allow
them to join, their circumstances are recounted here briefly.
fashion…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.4_1
4 pg
…054 make juvenile law enforcement
records confidential from members of the public, and states that information obtained by a law
enforcement agent participating in the assessment of a juvenile is confidential. These statutes
apply to the police reports involving Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1134.0_5
2 pg
…s arguments, and allow Plaintiff to file these materials as it
has already ordered.
Maxwell asserts that Plaintiff’s proposed redactions do not remove “descriptions of
nonparty conduct to discern the identity of a given non-party.” ECF No. 1129…
giuffre-maxwell
gov.uscourts.nysd.447706.1289.0
3 pg
…current assertion that “Doe 171 has not received Doc.
211” demonstrably false.
Doe 171 also asserts that “Doe 171 has never been publicly associated with the scandalous
and intimate activities described in most or all of the Confidential Records.” Id…
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…Maxwell asserts that she will need time to review each Non-Party
Objection to decide whether or not to submit a Party Objection under section 2(e) of the Protocol,
but Maxwell is not required to file a separate Party…
giuffre-maxwell
gov.uscourts.nysd.447706.111.2
5 pg
…Civ. P., of the Rugged Thunderbolt External Hard Drive (“Rugged TBT Drive”)
Plaintiff asserts that he purchased and which is at the core of this putative consumer class
action. See DE 40. The parties have confirmed that Plaintiff’s deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…the
Ransome deposition, the Emails should be disclosed at the same time to allow the public to
understand the full context of Ms. Ransome’s testimony, and to assess the credibility (or lack
thereof) of Ms. Ransome. Ms. Giuffre should…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…this case is the most expeditious manner in which to pursue their rights. Because
the background regarding their abuse is relevant to the Court’s assessment of whether to allow
them to join, their circumstances are recounted here briefly.
fashion…
giuffre-maxwell
gov.uscourts.nysd.447706.997.0
5 pg
…Plaintiff cites for that bald proposition the following language (quoted here from
Plaintiff’s brief in its entirety): “‘Insofar as the District Court held that these materials are not
1
The Plaintiff also asserts that our “arguments are unnecessary,” id…
giuffre-maxwell
1320-9
10 pg
…this case is the most expeditious manner in which to pursue their rights. Because
the background regarding their abuse is relevant to the Court’s assessment of whether to allow
them to join, their circumstances are recounted here briefly.
fashion…
giuffre-maxwell
gov.uscourts.nysd.447706.140.3
4 pg
…at issue; rather, an in camera
assessment of the disputed documents was deemed necessary to weigh whether the particular requested documents are
shielded by a public-interest privilege against disclosure of confidential communications. 4
The public interest privilege applied, in…
giuffre-maxwell
gov.uscourts.nysd.447706.185.8
24 pg
…herself has waived the
privilege by making repeated and voluntary statements about her allegations about being a “sex
2
Plaintiffs filed a privilege log in this lawsuit that broadly and only categorically asserts the
attorney-client and work product privileges…
giuffre-maxwell
gov.uscourts.nysd.447706.1290.0
3 pg
…18, 2022 ore tenus unsealing order. Doe 171
simply asserts that she “believes that the Court was misled or mistaken in determining that further
unsealing as to Doe 171 was warranted” based on “implicit assumptions.” Dkt. 1285 at 2.
However…
giuffre-maxwell
gov.uscourts.nysd.447706.610.0
3 pg
…assumed to have supported their papers with admissible
evidence”). “If the rationale behind access is to allow the public an opportunity to assess the
correctness of the judge’s decision, documents that the judge should have considered or relied
1…
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