gov.uscourts.nysd.447706.1199.18_1.pdf PDF
…Q. -- through here as GM -- 19 A. Yes. 20 Q. -- just by the initials, are we able to 21 safely know that that is Ghislaine Maxwell? 22 A. Yes. 23 MR. PAGLIUCA: Object to form and 24 foundation. 25 MR…
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gov.uscourts.nysd.447706.949.0.pdf PDF
…My client and my reporter write 16 about those things all the time. She writes about children. 17 She writes about public officials whose information needs to be 18 redacted for safety purposes. 19 But the bottom line, your Honor…
gov.uscourts.nysd.447706.63.0.pdf PDF
…known Prime Minister and other world leaders.” Plaintiff refused, claiming every applicable privilege, and additionally “because naming some such individuals would jeopardize her physical safety based on credible threats to the same (sic).” Menninger Decl. Ex. A at 12-13…
gov.uscourts.nysd.447706.78.0.pdf PDF
…receiving Defendant’s Motion to Compel. 7 Case 1:15-cv-07433-LAP Document 78 Filed 04/04/16 Page 13 of 30 because she had received credible threats to her safety and was concerned about revealing her location…
gov.uscourts.nysd.447706.1057.0.pdf PDF
… Martindell, 594 F.2d at 295-97. The courts have an obligation to safeguard the integrity of criminal investigations and the privacy and safety of witnesses and suspects that are part of those investigations. United States v. Longueuil, 567 F…
gov.uscourts.nysd.447706.1218.12.pdf PDF
…notice anything to my 20 law office for Virginia. She's had some safety 21 issues with respect to her location so we're not 22 going to be putting that on the record. 23 MS. BORJA: That's fine…
gov.uscourts.nysd.447706.76.1.pdf PDF
…whether she will reveal here address to Defendant’s counsel confidentially and we will update you with her response. a. Due to safety concerns with respect to Ms. Giuffre and her minor children, she is not at liberty to reveal…
gov.uscourts.nysd.447706.23.0.pdf PDF
…Ultimately, Ms. Giuffre escaped. Several years later, having gained a sense of safety and perspective, Ms. Giuffre sought to join a long-running Crime Victims’ Rights Act (“CVRA”) lawsuit, which was brought by other young girls who were also abused…
gov.uscourts.nysd.447706.135.0.pdf PDF
…Consequently, New York law applies to all of Plaintiff's privilege ~laims. ; .~ -. . . ~ IV. Applicable Sti:l.ndali(:t …
gov.uscourts.nysd.447706.1078.0.pdf PDF
…Id. Judge Nathan said she would ensure “strict compliance” with the rules and “ensure that the Defendant’s right to a fair trial will be safeguarded.” Id. On July 8 the government filed a superseding indictment alleging that Ms. Maxwell…
gov.uscourts.nysd.447706.1028.0.pdf PDF
…e.g., to his or her privacy, reputation, livelihood, and even safety. Unsealing is forever. Therefore, we respectfully submit, given the significant potential and irreversible implications to the Non-Parties, the Court should be over-inclusive and hesitant to remove…
1320-37.pdf PDF
…whether she will reveal here address to Defendant’s counsel confidentially and we will update you with her response. a. Due to safety concerns with respect to Ms. Giuffre and her minor children, she is not at liberty to reveal…
1320-40.pdf PDF
…Royal Palm Beach (Florida) Police Department, the County Court in and for Palm Beach County (Florida), the Greenacres (Florida) Department of Public Safety, and the Fremont County (Colorado) Sheriff’s Office. 9. Employment records obtained from ET Employment Training and…
gov.uscourts.nysd.447706.71.3.pdf PDF
…harass and intimidate Ms. Giuffre who was a victim of sexual trafficking. a. Due to safety concerns with respect to Ms. Giuffre and her minor children, she is not at liberty to reveal her present residential location. To ensure that…
gov.uscourts.nysd.447706.42.0.pdf PDF
…July 20, 2015) (denying motion to compel response to interrogatory that required identification of all documents that “relate to” drills or safety security training exercises “over a decade long span,” and holding that interrogatory was “facially overbroad, and potentially sweep…
gov.uscourts.nysd.447706.235.3.pdf PDF
…whether she will reveal here address to Defendant’s counsel confidentially and we will update you with her response. a. Due to safety concerns with respect to Ms. Giuffre and her minor children, she is not at liberty to reveal…
gov.uscourts.nysd.447706.140.3.pdf PDF
…school construction authority and target of its investigation that confidentiality was necessary to the pending investigation and vital to public safety because it encouraged potential witnesses to provide information to the authority’s inspector general was insufficient to invoke the…
gov.uscourts.nysd.447706.148.0.pdf PDF
…of sources, to protect witness and law enforcement personnel, to safeguard the privacy of individuals involved in an investigation, and otherwise to prevent interference with an investigation.” See In re Dep't of Investigation of City of N.Y., 851…
gov.uscourts.nysd.447706.45.0.pdf PDF
…July 20, 2015) (denying motion to compel response to interrogatory that required identification of all documents that “relate to” drills or safety security training exercises “over a decade long span,” and holding that interrogatory was “facially overbroad, and potentially sweep…
gov.uscourts.nysd.447706.589.0.pdf PDF
…298 (2d Cir. 2011) cuts against Cernovich’s argument as the Court stated: “Accordingly, we have recognized that “a person's physical safety” as well as “the privacy interests of individuals” such as witnesses, third parties, and those investigated in…
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