giuffre-maxwell
gov.uscourts.nysd.447706.1062.0
7 pg
…reason.” Id. at 319. Dershowitz asserts that the Maxwell Protective Order is a “blanket order”
that covers “all” documents “without consideration as to whether a specific document actually
contains justifiably confidential material.” Maxwell, DE 1058-1 at 2. Not so…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…without revealing information itself privileged or
protected, will enable the parties to assess the claim.” Ms. Ransome and her five attorneys
admittedly did not expressly make any such claim nor did they describe the nature of the
withheld documents.
The…
giuffre-maxwell
gov.uscourts.nysd.447706.1225.0
2 pg
…submissions on the docket. Any objections must be public to allow Intervenors and the
public to assess the form and merit of the objections being made and meaningfully respond to
them.
Sincerely yours,
HOLLAND & KNIGHT LLP
…
giuffre-maxwell
gov.uscourts.nysd.447706.1067.0
10 pg
…Merit.
Ms. Maxwell asserts objections based on alleged “countervailing interests” that are not
recognized in the extensive body of case law addressing whether a judicial document may be
sealed by the Court.
A. Reliance on a Protective Order By a…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…with an express finding that the [defamation] was intended to injure plaintiff and did in fact
cause injury, authorizes the jury to consider and assess punitive damages without any finding of
a specific amount of compensatory damages." Lawnwood Med. Ctr.…
giuffre-maxwell
gov.uscourts.nysd.447706.164.0
29 pg
…and Work Product Privileges
by Putting Plaintiff’s Representation At Issue in the Dershowitz Case
“The [attorney-client] privilege may implicitly be waived when [a party] asserts a claim
that in fairness requires examination of protected communications.” United States v…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
… Mr. Cassell asserts that the Palm Beach Police Report “showed the sexual
abuse was occurring on a daily basis” at the Epstein mansion, and thus “that [it] would have
made it obvious to a visiting guest that young girls were…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.9
15 pg
…without revealing information itself privileged or
protected, will enable the parties to assess the claim.” Ms. Ransome and her five attorneys
admittedly did not expressly make any such claim nor did they describe the nature of the
withheld documents.
The…
giuffre-maxwell
gov.uscourts.nysd.447706.68.0
17 pg
…shown defamation may recover at least nominal damages,’” and confirming an award of punitive
damages) (internal citation omitted). “In assessing the amount of damages to award for
defamation, a jury is not limited to compensating the plaintiff for ‘economic’ losses…
giuffre-maxwell
gov.uscourts.nysd.447706.46.0
22 pg
…s agent Ross Gow on communications with her attorney destroyed
the privilege, despite binding New York law to the contrary. Plaintiff asserts that Ms. Maxwell
and Mr. Epstein and their counsel were not in a common interest agreement without once…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…available
to district courts in protecting the integrity of the judicial process, and
emphasize the courts’ responsibility to exercise these powerful tools.
We also caution the public to critically assess allegations contained in
judicial pleadings.
9 Nixon v. Warner Commcʹns…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…evidence
comes out, it will be clear why Ms. Maxwell and others who enabled Jeffrey
Epstein are fighting so hard to keep it concealed. As our client Virginia Giuffre
bravely asserts, they did not act alone.”
Id. Ms. McCawley also…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.32
27 pg
…the privileged or protected, will enable the parties to assess the claim.
order must protect a person who is neither a party nor a party's officer from (B) Information Produced. If information produced in response to a
significant expense…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.18
23 pg
…was
14 applicable .
15 So what we have here is qualified privileges being
16 asserted as to defamatory statements. The two qualified
17 privileges she asserts are the self-defense privilege and the
18 prelitigation privilege. So in other words…
giuffre-maxwell
gov.uscourts.nysd.447706.223.1
14 pg
…directed in the order, und lhe privileged or protected, will enable the parties to assess ille claim.
order mllst protect a person who is neither II pHny nor a party'~ "metr tiol!) (U) Information Produced. If information produced in…
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…2020 [dkt. no.
1111-1].) The USVI asserts in its CICO action that Epstein ran a
criminal sex trafficking operation in the Virgin Islands, “wherein
he used his vast wealth and property holdings and a deliberately
opaque web of corporations…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…Federal Rules of Civil
Procedure provides that the court may impose a range of sanctions, including dismissal or
judgment by default, preclusion of evidence, imposition of an adverse inference, or assessment
of attorneys' fees and costs. Fed. R. Civ. P…
giuffre-maxwell
gov.uscourts.nysd.447706.946.0_1
14 pg
…Maxwell argues that "Miami Herald has no hope
of carrying its burden of unsealing every sealed document. Because it has not seen each document
it has no ability to assess whether a particular document is a judicial document…". Opp…
giuffre-maxwell
gov.uscourts.nysd.447706.406.0
31 pg
…Cir. 2006) (noting that if a court finds
documents to be judicial, it must then assess the weight of the presumed access and determine if
countervailing factors override the presumption).
Once again, Dershowitz’s own cited cases are his undoing…
giuffre-maxwell
gov.uscourts.nysd.447706.63.0
22 pg
…Interrog. No. 6) and whether Plaintiff has been defamed by anyone other than
1
Plaintiff additionally asserts that no interrogatories are permitted pursuant to Local Rule 33.3
prior to the last 30 days of discovery. See Menninger Decl. Ex…