giuffre-maxwell
gov.uscourts.nysd.447706.1197.0_1
1 pg
…following personal data identifiers: Social Security
numbers; dates of birth; minors’ names; and financial account numbers. See Federal Rule of Civil Procedure
5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information…
giuffre-maxwell
gov.uscourts.nysd.447706.946.0_1
14 pg
…6, 7
Lytle v. JPMorgan Chase,
810 F. Supp. 2d 616 (S.D.N.Y. 2011) ................................................................................................ 3, 6
Natixis Financial Products LLC v. Bank of America, N.A.,
10 Civ. 3656, 2016 WL 7165981 (S.D.N.Y., Dec. 7…
giuffre-maxwell
gov.uscourts.nysd.447706.1022.0
1 pg
…following personal data identifiers: Social Security
numbers; dates of birth; minors’ names; and financial account numbers. See Federal Rule of Civil Procedure
5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…the subpoena served on Ms. Ransome seeks documents that are wholly
irrelevant to the underlying action including protected financial information and documents or
communications between Sarah Ransome and her attorneys, which are protected by the attorney-
client privilege and the…
giuffre-maxwell
gov.uscourts.nysd.447706.32.0
1 pg
…following personal data identifiers: Social-
Security numbers; dates of birth; minors’ names; and financial account numbers. See Federal
Rule of Civil Procedure 5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to
request redaction of other information…
giuffre-maxwell
gov.uscourts.nysd.447706.1187.0
3 pg
…agree to unseal the identities of non-party Does where that
information is still sealed in Maxwell:
As used in this Protective Order, the term
“Confidential Information” includes (i) private
financial information, such as tax records and bank
account numbers…
giuffre-maxwell
gov.uscourts.nysd.447706.232.1
…10
Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms.
Giuffre objects to this request in that it is overly broad and seeks confidential financial
information. Ms. Giuffre objects to this interrogatory in that…
giuffre-maxwell
gov.uscourts.nysd.447706.1253.0
12 pg
…that Does 73 and 93 were not “involved in any of the conduct underlying this action” or
“accused of any wrongdoing” because they worked for Epstein in a “financial capacity” or because
Plaintiff could not remember their names at deposition.
…
giuffre-maxwell
gov.uscourts.nysd.447706.75.0
31 pg
…14
2. Allegedly “copyrighted” “proprietary” and “confidential” materials ............................ 15
C. Plaintiff must produce medical information and records, financial information, and
employment information and information on other potential causes of her injuries based
on her damages claims. .…
giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…Court, and/or that
plaintiff submitted to the Court for no valid purpose. The Sealing Opponents’ reputational
(Dershowitz) and financial (the other Opponents) interests are diametrically opposed to
Ms. Maxwell’s and the non-parties’.
Because of their respective motivations…
giuffre-maxwell
gov.uscourts.nysd.447706.363.6
15 pg
…15
15. Defendant also demands items like personal financial documents from this non-party
including payments she received from convicted sex offender Jeffrey Epstein and the men he
“lent” this minor child out to from 1999 – 2002. See Exhibit 6…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…10
Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms.
Giuffre objects to this request in that it is overly broad and seeks confidential financial
information. Ms. Giuffre objects to this interrogatory in that…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…to why certain portions of her deposition are
“personal,” “most of the cases in which courts have concluded that the privacy interests of
individuals were sufficient to overcome the presumption of access involve illness or sensitive
personal financial information.” Lytle…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…worked for or been in control of Ms. Maxwell.
x Ms. Maxwell and Mr. Epstein have had no financial, professional or employment
relationship in more than a decade, many years before 2015 when the purportedly
defamatory statement was published. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…party's claim or defense such that a reasonable
trier of fact could find that it would support that claim or defense.” Id. (citing Residential
Funding Corp. v. DeGeorge Financial Corp., 306 F.3d 99, 108 (2d Cir. 2002)).
Furthermore…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…assertions about me, other examples of her lack of credibility are relevant.
53. In the first place, Ms. Giuffre has been demonstrated to have made up
wildly implausible tales for financial gain. In 2011, for example, Ms. Giuffre was interviewed…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.26
28 pg
…destroyed
Hollywood Prince
Charlie Sheen
…
giuffre-maxwell
gov.uscourts.nysd.447706.1254.0
18 pg
…sealed.
19 Doe 73. This Doe worked for Epstein in a financial
20 capacity and there is no allegation that he was involved in any
21 of the conduct underlying this action. Given the sensitive and
22 potentially salacious issues…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.33
12 pg
…party's claim or defense such that a reasonable
trier of fact could find that it would support that claim or defense.” Id. (citing Residential
Funding Corp. v. DeGeorge Financial Corp., 306 F.3d 99, 108 (2d Cir. 2002)).
Furthermore…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.1
8 pg
…reasonable
trier of fact could find that it would support that claim or defense.” Id. citing Residential Funding
Corp. v. DeGeorge Financial Corp., 306 F.3d 99, 108 (2d Cir. 2002).
An adverse inference is appropriate regarding the documents that…