giuffre-maxwell
gov.uscourts.nysd.447706.232.1
…the nature of the Income, whether a loan, investment proceeds, legal settlement, asset sale,
gift, or other source.
Response to Interrogatory No. 10
Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms.
Giuffre objects…
giuffre-maxwell
gov.uscourts.nysd.447706.542.8
4 pg
…of Victims Refuse Silence, Inc., assets shall be distributed for one or more exempt purpose within
the meaning of section 501( c)( 3) of the Internal Revenue Code, or corresponding section of any future federal tax
code, or shall be…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…whether a loan, investment proceeds, legal settlement, asset sale, gift, or
other source.
11. Identify any facts upon which You base Your contention that You have suffered
as a result of the Alleged Defamation by Ghislaine Maxwell “past and future…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…in this action. First and most
fundamentally, the Jane Doe 43 action seeks millions if not hundreds of millions worth of assets
as “civil forfeiture.” It appears (although Ms. Ransome refused to answer) that she is
unemployed, with no source…
giuffre-maxwell
gov.uscourts.nysd.447706.1118.0
21 pg
…or compelling need’ justifying
modification of the protective order.” Id. (emphasis added). The USVI wholly ignores its burden
and the reasons therefor as set out in Martindell. Instead, it cites to inapplicable cases where
private parties seek to assert public…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.30
19 pg
…in this action. First and most
fundamentally, the Jane Doe 43 action seeks millions if not hundreds of millions worth of assets
as “civil forfeiture.” It appears (although Ms. Ransome refused to answer) that she is
unemployed, with no source…
giuffre-maxwell
gov.uscourts.nysd.447706.1003.0
1 pg
…in Giuffre v. Dershowitz,
19 Civ. 3377. As set forth in her earlier filings, Giuffre supports the unsealing of this case’s docket.
See Dkt. 995 at 7 (“[A]ll of the documents in question are judicial documents, and accordingly…
giuffre-maxwell
gov.uscourts.nysd.447706.1100.1
13 pg
…which are
not to be further transmitted to anyone other than Defense
Counsel;
c) Shall not be disclosed or distributed in any
form by the Defendant or her counsel except as set forth in
paragraph 1(d) below;
d) May…
giuffre-maxwell
gov.uscourts.nysd.447706.1235.0
2 pg
…this
Court’s November 5, 2021 order. The November 5, 2021 order is
amended and superseded as set forth below.
The parties shall first file briefs addressing the
objections of the following non-parties: Does 17, 53, 54, 55,
56…
giuffre-maxwell
gov.uscourts.nysd.447706.1119.0_3
4 pg
…291, 296 (2d Cir. 1979)). In determining whether
such extraordinary circumstances exist, the trial court considers several factors, as set out in In re
Ethylene Propylene Diene Monomer (EPDM) Antitrust Litig., 255 F.R.D. 308, 318 (D. Conn.
2009)…
giuffre-maxwell
gov.uscourts.nysd.447706.1318.0
3 pg
…1283). The following are the Courts findings as to
the Does designated following its particularized review of the
documents noted: as set forth herein. The Court stays its order
for fourteen days to permit any impacted Doe the opportunity to…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.12
7 pg
…to appoint a
special master to preside over the deposition to provide immediate rulings on any objections that
may arise regarding questions that are outside of the scope of the deposition as set forth in this
Court’s March 23…
giuffre-maxwell
gov.uscourts.nysd.447706.106.0
2 pg
…to compel Defendant to Produce Documents
Subject to Improper Objections, filed February 26 , 2016, ECF No.
35, was granted in part and denied in part as set forth in open
court on March 17, 2016. See ECF Nos. 66, 98…
giuffre-maxwell
gov.uscourts.nysd.447706.1323.0
2 pg
…filed by Intervenors Julie Brown and Miami Herald Media Company (hereinafter
collectively referred to as “Herald”) requesting that the Court unseal Docket Entry 1026-3.
Dershowitz adopts the rationale and arguments as set forth within the Herald’s letter motion…
giuffre-maxwell
gov.uscourts.nysd.447706.1317.0
3 pg
…1283). The following are the Courts findings as to
the Does designated following its particularized review of the
documents noted: as set forth herein. The Court stays its order
for fourteen days to permit any impacted Doe the opportunity to…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.29
24 pg
…matter of every
kind and description, graphic and oral records and representations of any kind, and electronic
“writings” and “recordings” as set forth in the Federal Rules of Evidence, including but not
limited to, originals or copies where originals are…
giuffre-maxwell
gov.uscourts.nysd.447706.1305.0
4 pg
…and MIAMI HERALD MEDIA COMPANY,
Intervenors-Appellees. *
*
The Clerk of Court is directed to amend the caption as set forth above.
1
MANDATE ISSUED ON 08/23/2023
Case
Case 22-…
giuffre-maxwell
gov.uscourts.nysd.447706.1050.0
12 pg
…10 be really limited. It could be nine or ten days to make that
11 request, and therefore renew the request to extend it just
12 briefly as set forth in our letter.
13 THE COURT: Yes, sir. Who else…
giuffre-maxwell
gov.uscourts.nysd.447706.1240.0
5 pg
…Supp. 2d at 621–22.
As set forth below, the Does have failed to meet the burden to demonstrate that any of these
documents should remain sealed.
Generalized Privacy Concerns Do Not Warrant Sealing
This Court has already held that…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.28
24 pg
…matter of every
kind and description, graphic and oral records and representations of any kind, and electronic
“writings” and “recordings” as set forth in the Federal Rules of Evidence, including but not
limited to, originals or copies where originals are…
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