giuffre-maxwell
gov.uscourts.nysd.447706.1331.4
21 pg
…1-8.
Yet while these issues were before the Court by (at least) May, Defendant waited an
additional seven months to file this motion that she claims should result in the complete
dismissal of this action. Such delay is unreasonable…
giuffre-maxwell
gov.uscourts.nysd.447706.513.0
21 pg
…May 2016,
Yet while these issues were before the Court by (at least) May, Defendant waited an
additional seven months to file this motion that she claims should result in the complete
dismissal of this action. Such delay is unreasonable…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.37
9 pg
…purpose
of Florida statutes. See Rubrecht, supra, 95 So. 3d at 956.
Finally, in addition to striking Dershowitz's pleadings. striking his affidavit, and awarding
attorneys' fees, Ms. Giuffre requests that the Court admonish Dershowitz that any further
violations of…
giuffre-maxwell
gov.uscourts.nysd.447706.2.0
2 pg
…D Dismissed . No D Yes D If yes, give d a t e - - - - - -- - -- & Ca se No . .
Is THIS AN INTERNATIONAL ARBlT RATION CASE! No @ Yes D
(PLACE AN {x] IN ONE BOX ONLY> NATURE OF SUIT
TORTS …
giuffre-maxwell
gov.uscourts.nysd.447706.57.1
26 pg
…R. dissenting) dismissed an appeal
by the plaintiff from Donaldson J.'s order.
On appeal by the plaintiff: —
Held, allowing the appeal, that the due administration of
justice strongly required that a document such as the internal
inquiry report, which…
giuffre-maxwell
gov.uscourts.nysd.447706.509.0
18 pg
…injury to the
3
Residential Funding has been superseded by statute with respect Electronically Stored Information
(“ESI”) in the 2015 amendments to 37(e) of the Federal Rules of Civil Procedure, which now require willful or
purposeful destruction of ESI…
giuffre-maxwell
gov.uscourts.nysd.447706.555.0
21 pg
…3
Residential Funding has been superseded by statute with respect Electronicall y Stored Information
I ("ESI") in the 2015 amendments to 37(e) of the Federal Rules of Civil Procedure, which now require willful or
purposeful destruction of ES I…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…TO INTERVENE TO STRIKE
ALLEGATIONS RELEVANT TO ISSUES PENDING BEFORE THE COURT.
The Court should also deny Dershowitz’s motion for intervention because it would be a
pointless exercise.
Citing Rule 12(f) of the Federal Rules of Civil Procedure…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.8
29 pg
…statute is irrelevant here. One, the identifying information in the police reports in this
case was redacted. Two, the case at bar is an “open judicial proceeding”2 involving Plaintiff as
an alleged sexual crime victim, and a number of…
giuffre-maxwell
gov.uscourts.nysd.447706.551.0
17 pg
…motion, the court may permit anyone to intervene who
is given a conditional right to intervene by a federal statute or has a claim or defense that shares
with the main action a common question of law or fact.” Fed…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.20
21 pg
…The conduct expl i citly described by statute as
privileged does not operate as waiver, and again Defendant has
provided no factual basis to suggest Plaintiff has
misrepresented the identity or role of the third-parties listed .
Defendant ' s request…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.9
21 pg
…The conduct explicitly described by statute as
privileged does not operate as waiver, and again Defendant has
provided no factual basis to suggest Plaintiff has
misrepresented the identity or role of the third-parties listed .
Defendant's request is denied…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.15
43 pg
…extent to which Ms. Giuffre can use the documents.
3
Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 6 of 43
Federal Rule of Civil Procedure 26 authorizes a court, for good cause…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…is codified under Florida's Title VII Evidence. The
statute provides that neither an attorney nor a client may be compelled to divulge confidential
communications between a lawyer and client which were made during the rendition of legal
services. Fla…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.9
21 pg
…The conduct explicitly described by statute as
privileged does not operate as waiver, and again Defendant has
provided no factual basis to suggest Plaintiff has
misrepresented the identity or role of the third-parties listed.
Defendant's request is denied…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…potions, discussed below, is
met – the information is highly relevant, critical to the defense, and available form no other source.
5
Case 1:15-cv-07433-LAP Document 1325-1 Filed 01/04/24 Page 8 of 21
C…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…Sys., Inc.,
752 F.2d 16 (2d Cir. 1984) .................................................................................................. 10, 11
4
Case 1:15-cv-07433-LAP Document 1259 Filed 07/28/22 Page 5 of 17
STATUTES
18 U.S.C. § 2 .…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.10
64 pg
…19 In fact, Globe Newspaper was the Supreme Court case
20 that specifically held that a Massachusetts statute that
21 automatically sealed material relating to sexual assault of
22 minors does not pass muster. We have to look at an…
giuffre-maxwell
gov.uscourts.nysd.447706.702.0
63 pg
…19 In fact, Globe Newspaper was the Supreme Court case
20 that specifically held that a Massachusetts statute that
21 automatically sealed material relating to sexual assault of
22 minors does not pass muster. We have to look at an…
giuffre-maxwell
gov.uscourts.nysd.447706.57.2
30 pg
…it.
d. It would continue to cover cases such as Gotha City and the examples discussed
in that case. In Gotha City, the apparent owner of a picture wished to sell it
through Sothebys. It took advice from Messrs Herbert…
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