giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…not “was wholly irrelevant” to Boies’s involvement in court.
Separately, Dershowitz took issue with the way he said Boies’ firm approached him after Roberts’ claims
first arose in late 2014. Dershowitz said that one of Boies Schiller’s lawyers…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…including the age and professional
qualifications, of their employees.
10. Have you ever recruited, found, hired, approached, introduced, procured, or
otherwise obtained, for the purposes of Jeffrey Epstein employing, any female who was not
at the time a certified or…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.9
6 pg
…beggars belief.
No document has ever been contemplated, created nor lawyer nor other approached to write such a
document at anytime
THE TERRAMAR PROJECT
FACEBOOK
TWITTER
G+
PINTEREST
INSTAGRAM
PLEDGE
THE DAILY CATCHthe
From: J Jep
Date: Wednesday, April 22…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.10
64 pg
… If we had planned for this to be a
25 month long case, I think we would have approached this
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 1332-10 Filed 01…
giuffre-maxwell
gov.uscourts.nysd.447706.702.0
63 pg
… If we had planned for this to be a
25 month long case, I think we would have approached this
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-RWS Document 702 Filed 03/08…
giuffre-maxwell
gov.uscourts.nysd.447706.1005.0
6 pg
…been categorical and succinct. It was neither. The decision turned on the Second Circuit’s
lengthy discussion of the First and Third Circuits’ divergent approaches to the question, when
is a mere document transformed into a judicial one? The Third…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…at 119-20. It is a given
accepted by the Protective Order that the trial and all trial
documents are accessible and public absent special
circumstances.
Under the common law approach, once a document is
classified as a judicial document…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…been categorical and succinct. It was neither. The decision turned on the Second Circuit’s lengthy
discussion of the First and Third Circuits’ divergent approaches to the question, when is a mere
document transformed into a judicial one? The Third…
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.447706.995.0
11 pg
…As a result, John Doe is in no position
to speculate (let alone dictate) how the Court should approach and consider the categories of
documents that the parties have agreed upon, to say nothing of offering wholly new categories for…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…The parties in Dershowitz have done just that and have presented a “reasonable”
approach in which Giuffre has no objection to producing certain enumerated categories from
among the Maxwell confidential materials and sealed filings in her possession so long as…
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.447706.1332.11
9 pg
…2017, followed up on this by presenting argument on the Motion to Compel
that relied almost entirely on the rules-violating reply.
Because of the unfairness from plaintiff’s chaotic approach to motion practice, we
requested on March 9 leave…
giuffre-maxwell
gov.uscourts.nysd.447706.1188.0
3 pg
…Plaintiff’s ad hoc approach
that picks and chooses among Non-Parties will more likely to lead to confusion and inefficiency
in lieu of an orderly and logistical progression of unsealing.
Defendant instead offers two alternatives for selecting the pleadings…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…the order that their name appears on the Non-Party list. Id. at
1-2. Under Maxwell’s approach, the public will not have access to those documents, to which they
have a First Amendment right of access, for years…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…2019) (quoting Newsday LLC v. County
of Nassau, 730 F.3d 156, 163 (2d Cir. 2013)). In the Second Circuit, courts utilize two methods
approaching the First Amendment right. Doe, 2019 U.S. Dist. LEXIS 36605, at *3. The
“experience…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.13
22 pg
…3. The government could have been, but was not, more
targeted in its approach. The government has not provided Maxwell with a copy of the subpoena,
but the record shows that the subpoena was incredibly broad and, as explained below…
giuffre-maxwell
gov.uscourts.nysd.447706.1105.0
8 pg
…participation.
And, indeed, precedent mandates the protocol’s approach: “[t]he job of protecting [non-
party privacy rights] rests heavily upon the shoulders of the trial judge.” In re New York Times
Co., 828 F.2d 110, 116 (2d Cir…
giuffre-maxwell
gov.uscourts.nysd.447706.1071.0
13 pg
…of the discovery from Maxwell,”” he has not
beyond conclusory assertions demonstrated a congruence between the
Maxwell action and his own that would warrant such an
indiscriminate approach.
A brief comparison of the Maxwell and Dershowitz actions makes
this clear…