…Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ____________________________/ DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF PLAINTIFF’S MOTION IN LIMINE TO ADMIT THE “BLACK BOOK” AS …
…time & travel records, victim notification letters, and a black book. This reference to evidence is otherwise discussed in publicly available articles and even the public docket entries in this case. 2 Case 1:15-cv-07433-LAP Document 833…
…criminal prosecution broke), Dershowitz stated “I’m on my 20th book … The only person outside of my immediate family that I send drafts to is Jeffrey.”5 Dershowitz has also been quoted as saying that, even if Epstein went…
…Tayler filed a federal 6 lawsuit against Julie Brown, the reporter, and Harper Collins 7 alleging that Ms. Brown's book, Perversion of Justice, contains 8 allegedly defamatory statements about Ms. Tayler and her 9 alleged association with Jeffrey Epstein…
…Tayler filed a federal 6 lawsuit against Julie Brown, the reporter, and Harper Collins 7 alleging that Ms. Brown's book, Perversion of Justice, contains 8 allegedly defamatory statements about Ms. Tayler and her 9 alleged association with Jeffrey Epstein…
…criminal prosecution broke), Dershowitz stated “I’m on my 20th book … The only person outside of my immediate family that I send drafts to is Jeffrey.”5 Dershowitz has also been quoted as saying that, even if Epstein went…
…Before: 0 pt, Line spacing: Double The Parties acknowledge that this Order does not confer blanket protections on all Formatted: Font: 12 pt, Font color: Black Formatted: Indent: First line: 0.5", Space discl…
…public access absent a countervailing reason”) (emphasis supplied; internal quotations omitted). Brown’s Standard of Review - Non-Judicial and Negligibly Judicial Documents The Sealing Opponents see in black and white, where documents either are non-judicial documents or judicial documents…
…Before: 0 pt, Line spacing: Double The Parties acknowledge that this Order does not confer blanket protections on all Formatted: Font: 12 pt, Font color: Black Formatted: Indent: First line: 0.5", Space discl…
…are currently pending in the Second Circuit regarding the protective order, and appellants in several of the appeals have asked for (among other things) a remand back to this Court, apparently for further proceedings on what materials are to be…
…Once a document is posted to the docket, the information contained therein is pushed out to the greater public in a matter of moments. There is therefore no way to claw back information once it has been revealed. 1 Unfortunately…
…Maxwell, who had already been maintaining a low profile even before the Epstein scandal came roaring back to life this past summer.”2 1 https://www.vanityfair.com/news/2019/11/hunt-for-jeffrey-epstein-alleged-enabler- ghislaine-maxwell?utm…
…Dershowitz’s request to modify the Maxwell Protective Order, it will not in the same breath force him to litigate this action with one arm tied behind his back. 5 At a hearing before the Court on December 2, 2019…
…212) 805-0300 I59YGIUC Case 1:15-cv-07433-LAP Document 949 Filed 06/01/18 Page 10 of 31 10 1 over the United States, it provides for people coming back in 2 and saying, I challenge it…
…should therefore be proportionally narrow. While Mr. Dershowitz will not be forced to “litigate this action with one arm tied behind his back,” (dkt. no. 144 at 6 n.4), that does not require that the Court allow Mr. Dershowitz…
…document. DE 173-1 exhibits 1-4 identify additional Non-Parties. Generally, these exhibits are a composite of various back and forth emails between counsel which are hearsay, non-judicial, documents and which contain the identity of Non-Party Does…
…in 09:21:37 17· ·the drafting. 09:21:40 18· · · · Q.· ·Okay.· Could I ask you to please refer back to 09:21:41 19· ·Exhibit 2.· Looking also at Exhibit 9, Exhibit 9 appears 09:21:47 20…
…814 F.3d at 143-44 (attempt to seal complaint against law firm alleging that partners engaged in kick-back scheme was properly denied where complaint was of "legitimate interest to the public" and where disclosure would not reveal details…
…by-jeffrey-epstein-in-newly-released-2016-deposition/ 232 https://www.washingtonexaminer.com/policy/courts/ghislaine-maxwell-repeatedly-pushed-back-on-epstein-sexual-misconduct-allegations-unsealed-deposition-revea 233 https://www.mynspr.org/post/jeffrey-epstein-update-read-deposition-ghislaine…
…(The genie is out of the bottle . . . . We have not the means to put the genie back.”); see also Alcon Vision, LLC, 2020 WL 3791865, at *7–8 (finding documents already unsealed in a parallel MDL action should also be…
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