giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…Jane Doe #3
would prove the following:
In 1999, Jane Doe #3 was approached by Ghislaine Maxwell, one of the main women
whom Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator
in his…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…Jane Doe #3
would prove the following:
In 1999, Jane Doe #3 was approached by Ghislaine Maxwell, one of the main women
whom Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator
in his…
giuffre-maxwell
1320-9
10 pg
…Jane Doe #3
would prove the following:
In 1999, Jane Doe #3 was approached by Ghislaine Maxwell, one of the main women
whom Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator
in his…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.3
10 pg
…Jane Doe #3
would prove the following:
In 1999, Jane Doe #3 was approached by Ghislaine Maxwell, one of the main women
whom Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator
in his…
giuffre-maxwell
gov.uscourts.nysd.447706.139.0
7 pg
…here. Indeed, she cannot approach that standard,
as she has made no showing whatsoever of any compelling or particularized need for these
materials. Defendant is attempting to improperly interfere with an ongoing criminal investigation,
and under New York law, disclosure…
giuffre-maxwell
gov.uscourts.nysd.447706.1052.0
4 pg
…might be at the very bottom of the Non-
Party list. The Court would need to make 15 separate rulings before Docket Entry 143 is unsealed.
s approach, all Non-Parties mentioned in the First Five
Motions would be notified…
giuffre-maxwell
gov.uscourts.nysd.447706.1045.0
2 pg
…Plaintiff’s counsel proposes an ad hoc
approach in which filings appear to be selected in order to speed up review of materials that
Plaintiff would like to see unsealed first rather than a review method that favors efficiency and…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
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
gov.uscourts.nysd.447706.977.1
25 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.447706.1137.14_2
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
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
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
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.447706.978.0
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.447706.941.0
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.447706.977.0
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…
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