giuffre-maxwell
gov.uscourts.nysd.447706.604.0
11 pg
…to the third factor, previous alternatives were in place, where the parties
could propose narrowly tailored redactions. The parties have since disregarded this approach
and decided to seal entire pleadings without explanation or justification. And, as noted, there
have been…
giuffre-maxwell
gov.uscourts.nysd.447706.903.0
46 pg
…and all of that.
8 MR. PAGLIUCA: Exactly.
9 So, your Honor, if I could approach, I wanted to talk
10 about the nonprosecution agreement and why the nonprosecution
11 agreement, I think, ends this discussion.
12 In order to…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.40
30 pg
…Honor,
4 of just making a very short little cheat sheet of the
5 outstanding issues, if I may approach.
6 THE COURT: Yes. It will be interesting to see if
7 yours is the same as the one we…
giuffre-maxwell
gov.uscourts.nysd.447706.1028.0
5 pg
…a crime
victim.
Plaintiff and Ms. Maxwell have a fundamental difference in the approach to
identifying the non-parties who should be on the list. Plaintiff takes the position that
if a non-party’s name has appeared anywhere in…
giuffre-maxwell
gov.uscourts.nysd.447706.847.0
94 pg
…contains the seal
21 of the FBI at the top of it. It contains the date. Can I
22 approach, please.
23 It's a document that's commonly used when FBI agents
24 are conducting their investigations; in fact…
giuffre-maxwell
1320-18
40 pg
…discussed
below, as a matter of controlling federal authority, these cases have been repudiated by the
Second Circuit. And to the same effect, Florida law also rejects the expansive Hearn approach
to waiver. See Guarantee Ins. Co. v. Heffernan Ins…
giuffre-maxwell
1320-13
45 pg
…with
During a sworn taped statement, stated she met
Jeffrey Epstein through Haley Robson. Robson would approach females
who wished to work for him. ••■■~ stated she was asked to.work for
him but declined. •■■■9explained that work means give…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…which pertains to
a different subject or person, is as well. This approach is compelled by the particularized review
set forth by the Court of Appeals. See Brown, 929 F.3d at 49−51.
The second category of Sealed Materials consists…
giuffre-maxwell
gov.uscourts.nysd.447706.235.1
31 pg
…Honor,
4 of just making a very short little cheat sheet of the
5 outstanding issues, if I may approach.
6 THE COURT: Yes. It will be interesting to see if
7 yours is the same as the one we…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…P. 11. See also Amodeo II, 71 F.3d at 1049 (describing sanctions available
to the court).
45 Sonia Sotomayor & Nicole A. Gordon, Returning Majesty to the Law and
Politics: A Modern Approach, 30 Suffolk U. L. Rev. 35, 47…
giuffre-maxwell
gov.uscourts.nysd.447706.22.0
14 pg
…12/15/15 Page 7 of 14
Instead, as is apparent from the new and increasingly outlandish allegations raised in opposition,
Plaintiff clearly intends a “kitchen sink” approach to discovery. In a case such as this that
encompasses allegations dating…
giuffre-maxwell
gov.uscourts.nysd.447706.978.0
27 pg
…P. 11. See also Amodeo II, 71 F.3d at 1049 (describing sanctions available
to the court).
45 Sonia Sotomayor & Nicole A. Gordon, Returning Majesty to the Law and
Politics: A Modern Approach, 30 Suffolk U. L. Rev. 35, 47…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.13
35 pg
…then, to try to
11 establish whether or not there's
12 a good-faith basis.
13 Q. Did you approach Alan
14 Dershowitz for the purpose of seeking
15 legal advice?
16 A. I was introduced to Alan.
17…
giuffre-maxwell
gov.uscourts.nysd.447706.993.0
28 pg
…otherwise. This is the exact opposite of the presumption the law requires: public
access is presumed. It is also the polar opposite of the approach the Second Circuit followed. The
Second Circuit unsealed the summary judgment record in its entirety…
giuffre-maxwell
gov.uscourts.nysd.447706.136.0_2
29 pg
…Honor,
4 of just making a very short little cheat sheet of the
5 outstanding issues, if I may approach.
6 THE COURT: Yes. It will be interesting to see if
7 yours is the same as the one we…
giuffre-maxwell
gov.uscourts.nysd.447706.944.0
11 pg
…privacy interests of
those resisting disclosure.” Id. at 120.
The Second Circuit has established two approaches for determining whether the public
and press have a qualified First Amendment right to access certain judicial documents. The
“experience and logic” approach requires…
giuffre-maxwell
gov.uscourts.nysd.447706.941.0
6 pg
…Giuffre and Ms. Maxwell has settled,
it may be that all case-related documents and deposition testimony can simply be
released – an approach to which Ms. Giuffre is not opposed.
Supplemental Brief of Virginia Giuffre at 7 (emphasis in original…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.13
22 pg
…claims that portions of his
testimony that happen to be favorable to Ms. Giuffre are “outside the scope of his opinion.” This
pick-and-choose approach is not permitted, and Defendant is required to take the bitter with the
sweet…
giuffre-maxwell
gov.uscourts.nysd.447706.977.0
27 pg
…P. 11. See also Amodeo II, 71 F.3d at 1049 (describing sanctions available
to the court).
45 Sonia Sotomayor & Nicole A. Gordon, Returning Majesty to the Law and
Politics: A Modern Approach, 30 Suffolk U. L. Rev. 35, 47…
giuffre-maxwell
gov.uscourts.nysd.447706.436.0
15 pg
…support of any
part of the court’s adjudicatory function.” Rosado, 970 A.2d at 678 (emphasis added)
(describing the Second Circuit’s approach as consistent with Mokhiber). This explains the nearly
uniform consensus among the district courts bound by…
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