giuffre-maxwell
gov.uscourts.nysd.447706.371.2
18 pg
…foreign or domestic, directly or
indirectly held by You, or held on Your behalf or for Your benefit by another individual or
entity, including trusts from January 2015 to the Present.
RESPONSE: Ms. Maxwell objects to this Request on the…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.38
8 pg
…on privilege, he wagered that the consequences from this Court for his deliberate violation
of the settlement privilege would not be harsh enough to offset the benefit he received by feed ing
fa lse information to the press. On December…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…he had no role in issuance of the statement, he has
no benefit in the outcome of this litigation and he played no controlling role in its respect.
Similarly, there is not any evidence at all to support an adverse…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…fundamentally unfair to
allow Giuffre to continue to press these allegations where she and her attorneys have had the full
benefit of discovery already conducted concerning these allegations which is in her possession and
which is being withheld Dershowitz and…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…Inc., 285 B.R. 101, 109
(E.D.N.Y. 2002) (quoting United States v. Peoples Benefit Life Ins. Co., 271 F.3d 411, 415 (2d
Cir. 2001)).
Under Rule 24(b), courts in this Circuit consider the following factors…
giuffre-maxwell
gov.uscourts.nysd.447706.1353.0
6 pg
…Mar. 25, 2021).
3
There is no basis to believe that the protective order or subsequent sealing of documents were
imposed solely for Maxwell’s benefit; Judge McMahon discussed “Maxwell[’s] … degree of pro-
tection” because she “assume[d]…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.17
13 pg
…orders is broad. “When the district court
invokes its inherent power to sanction misconduct by an attorney that involves that attorney’s
violation of a court order or other misconduct that is not undertaken for the client’s benefit, the
…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…he had no role in issuance of the statement, he has
no benefit in the outcome of this litigation and he played no controlling role in its respect.
Similarly, there is not any evidence at all to support an adverse…
giuffre-maxwell
gov.uscourts.nysd.447706.406.0
31 pg
…confidence in the administration of justice.”). Indeed, the motion to intervene is
devoid of any citations to precedent that allows an individual to exploit these bedrock legal
principles solely for his personal benefit, rather than the public at large. Furthermore…
giuffre-maxwell
1320-28
32 pg
…he had no role in issuance of the statement, he has
no benefit in the outcome of this litigation and he played no controlling role in its respect.
Similarly, there is not any evidence at all to support an adverse…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…But, because he has
passed away, his family must confront these allegations and the associated stigma without the
benefit of Professor Minsky’s response, let alone an available forum for seeking redress.
Providing the media more unsubstantiated allegations, never leveled…
giuffre-maxwell
gov.uscourts.nysd.447706.222.0
10 pg
…other than the one selected by the party seeking discovery.” Even among parties, the Court has
discretion to impose discovery limitations where the “burden or expense of the proposed discovery
outweighs its likely benefit, considering the needs of the case…
giuffre-maxwell
gov.uscourts.nysd.447706.957.0
13 pg
…orders is broad. “When the district court
invokes its inherent power to sanction misconduct by an attorney that involves that attorney’s
violation of a court order or other misconduct that is not undertaken for the client’s benefit, the
…
giuffre-maxwell
gov.uscourts.nysd.447706.370.0
17 pg
…issues, and whether the
burden or expense of the proposed discovery outweighs its likely benefit.
Information within this scope of discovery need not be admissible in evidence to
be discoverable.
For information to be subject to a request to production…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.19
17 pg
…issues, and whether the
burden or expense of the proposed discovery outweighs its likely benefit.
Information within this scope of discovery need not be admissible in evidence to
be discoverable.
For information to be subject to a request to production…
giuffre-maxwell
gov.uscourts.nysd.447706.589.0
24 pg
…therwise, there would exhibit a danger that the court could become a partner in the use of the
subpoenaed material to gratify private spite or promote public scandal, with no corresponding
assurance of public benefit.” Nixon v. Warner Communications, Inc…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…DOC 291 and
studying its contents, that he cannot determine which documents implicate him in Epstein's
criminal conduct, negotiating the NPA for his own benefit and documents evincing Plaintiffs
investigation of him, is disingenuous. DOC 291 and its attachments…
giuffre-maxwell
gov.uscourts.nysd.447706.1214.0
7 pg
…by the Second
Circuit”).
These arguments are all unavailing. There is simply no benefit to debating whether
documents should be sealed when they are already widely disseminated on the courts’ public
dockets. See In re Application to Unseal 98 Cr…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…S.2d at 922. Ms. Maxwell’s case will not “rise or
fall” based on whether she can show that Ms. Roberts received a financial benefit from the
publication of her story. In any event, Ms. Maxwell may elicit testimony…
giuffre-maxwell
gov.uscourts.nysd.447706.872.0
76 pg
…the Court properly applied
Davis at the motion to dismiss sta ge, but argues that the third
factor, especially , benefits from the evidence presented in the
motion for summary judgment. See Def.'s Br. at 32. I n other
words…
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