giuffre-maxwell
gov.uscourts.nysd.447706.239.1
11 pg
…Epstein in Does.
Neither June 17 nor June 28 is an available date.
Regards,
Greg Poe
Please note: As of June 1,2016, my email address has changed to
[email protected]. Please update your address book accordingly.
Gregory L…
giuffre-maxwell
gov.uscourts.nysd.447706.2.0
2 pg
…docket sheet.
PLAINTIFFS DEFENDANTS
Virginia L. Giuffre Ghislai ne Maxwell
ATTORNEYS (FIRM NAME, ADDRESS. AND TELEPHONE NUMBER ATTORNEYS (IF KNOWN)
David …
giuffre-maxwell
gov.uscourts.nysd.447706.1330.9
6 pg
…contained in this e-mail and any attachments is confidential and may be privileged or otherwise
protected from disclosure. It is intended solely for the attention and use of the named addressee(s). If you are
not the intended recipient…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…Esq.
1 This daytime business address is provided for
identification and correspondence purposes only and is not
intended to imply institutional endorsement by the University of
Utah for this private representation.
Case 1:15-cv-07433-RWS
Case 1…
giuffre-maxwell
gov.uscourts.nysd.447706.160.0
12 pg
…18, 2016, at which time the investigator affixed the subpoena to the front door of
Epstein’s residence and mailed copies of the subpoena to both of his New York addresses along
with a witness check. Counsel for Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.28_4
5 pg
…may be attorney- client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited…
giuffre-maxwell
gov.uscourts.nysd.447706.223.6
4 pg
…his
rights to contest the breadth of the subpoena and whether a deposition should be required
at all given his articulated and principled intention to assert the Fifth Amendmentin
response to questions addressing the subject matter of the Giuffre v…
giuffre-maxwell
gov.uscourts.nysd.447706.992.0
5 pg
…Maxwell, 929 F.3d 41 (2019), and should be rejected out of hand.
This submission addresses the categories of filings set forth in Maxwell’s brief (ECF No. 991).
Categories 1 and 7: Motions to Compel and Related Discovery Motions…
giuffre-maxwell
gov.uscourts.nysd.447706.223.5
3 pg
…contest the breadth of the subpoena and
whether a deposition should be required at all given his articulated and
principled intention to assert the Fifth Amendment in response to questions
addressing the subject matter of the Giuffre v Maxwell lawsuit…
giuffre-maxwell
gov.uscourts.nysd.447706.1215.0
13 pg
…insufficient to render that paper
a judicial document subject to the right of public access.” She proclaimed that “[a] review of the
case law reveals that every circuit to have directly addressed this point has found that documents
1
Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.8
12 pg
…18, 2016, at which time the investigator affixed the subpoena to the front door of
Epstein’s residence and mailed copies of the subpoena to both of his New York addresses along
with a witness check. Counsel for Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.0
35 pg
…Case No. 20-2413,
ECF No. 68 (hereinafter, “Maxwell’s Appellate Br.”) at 15 (arguing that “the district court failed
to address or even acknowledge the reliance interests of those who, like Ms. Maxwell, sat for a
deposition confident in…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.15
43 pg
…8 l~]E_lJljE LOCATION , F
THE TR. CT OF LANI!,!N~ J;Y'fil't FT. lAUD,
(C) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (ff Known…
giuffre-maxwell
1320-8
12 pg
…18, 2016, at which time the investigator affixed the subpoena to the front door of
Epstein’s residence and mailed copies of the subpoena to both of his New York addresses along
with a witness check. Counsel for Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.551.0
17 pg
…should be sealed. Moreover, ECF No. 250 only address
“the names and identifying information of individuals”, yet the Summary Judgment documents
8
redact well in excess of that limited matter. No matter what standard the Court applies, Maxwell’s
Motion…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…Y.S.2d 5, 10 (1st Dep’t 2006). “[B]road
pronouncements” that fail to identify “a ‘significant issue’ in the case that the subpoenaed
materials potentially address” are not sufficient to satisfy this prong. In re McCray, Richardson,
Santana…
giuffre-maxwell
gov.uscourts.nysd.447706.689.0
42 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only
and is not intended to imply institutional endorsement by the University of Utah for this private
representation.
40
…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.1
8 pg
…was confident Farmer would stand up to cross-examination if
there’s a trial. Farmer, who addressed the court by telephone, urged the judge not
to grant Maxwell bail, calling her a ‘sexual predator who groomed and abused
me.’ Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…TGP
highlights that it is addressing this gap as a trusted news source for the stories and views that are
largely untold or ignored by traditional news outlets.5 One of its core values is that it “must have
courage…
giuffre-maxwell
gov.uscourts.nysd.447706.1213.0
18 pg
…with
information that would enable it to make such specific findings warranting continued sealing.
Thus, all arguments in favor of sealing documents aside from those specifically addressed in
Maxwell’s brief should be deemed waived, as Maxwell essentially concedes that…
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