…2d 16, 22 (2d Cir. 1984) - Televised coverage not allowed In addition, Cernovich cites cases concerning cameras in the courtroom – cases which have absolutely no bearing on the issue at hand. See Katzman v. Victoria’s Secret Catalogue, 923 F…
…9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------X ...... ......................................... VIRGINIA L. GIUFFRE, Pla…
…of 22 TABLE OF CONTENTS I. INTRODUCTION .............................................................................................................. 1 II. ARGUMENT .........................................................................................................…
…L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF, VIRGINIA GIUFFRE’S REDACTED BRIEF IN SUPPORT OF THE PRIVILEGE CLAIMED FOR HER IN CAMERA SUBMISSION Plaintiff Virginia L. Giuffre, by…
…Maxwell, No. 15 Civ. 7433, to submit to the Court for in camera review their comments on Defendant Alan Dershowitz’s request in Giuffre v. Dershowitz, No. 19 Civ. 3377, that Plaintiff Virginia Giuffre produce to him confidential discovery materials…
…Because those comments may discuss information that is currently under seal in Giuffre v. Maxwell, they will be submitted directly to the Court so that the Court can review them in camera. Comments may be sent to the Court’s…
…1 Exhibit, # 3 Exhibit) Motion to Compel NOTICE of In Camera Submission re: 134 Order,,. 05/04/2016 141 Improper Purpose - In Camera Document filed by Virginia L. Giuffre. Materials …
…Du ring argument, the Cour t held th at in camera review was warranted for purposes of 2 ., determining whether privilege applied to the do c um e nts in quest i on, and Defenda…
…current law enforcement investigation – Ms. Giuffre respectfully requests leave to provide such information to the Court via an ex parte, in camera submission. I. Background As the Court is well aware from previously filed pleadings, this is a single-count …
…vested any control in Mr. Epstein “in regard to key facts and subject matter of litigation.” As the Court is well aware from review of emails submitted in camera (and later produced to Plaintiff): o Mr. Epstein and his counsel…
…before it was filed in September of 2015, as evidenced by the email communications between Dershowtiz and Defendant the Court reviewed in its in camera review before ordering Defendant to produce them. Yet Dershowitz waited until after discovery closed and…
…Giuffre whose substance has already been widely aired in public—including, apparently, on camera to ABC News—and which have been widely circulated for sale to publishers and journalists. Ms. Giuffre’s efforts to gain publicity and a book deal…
…follows: Ms. Giuffre, in accordance with the Court’s direction at the hearing on April 21, 2016, has submitted documents to the Court for In Camera review. Ms. Giuffre met with the FBI on or about March 17, 2011. Ms…
…it was necessary for the rendering of legal advice, I'll 15 review those materials in camera and try to reach a decision. 16 I may need something further after I have looked at them, but I 17 think that…
…heard and the motion granted in part and denied in part on April 21 , 20 16. Plaintiff was directed to submit the relevant materials for in camera review. Plaintiff did so on April 28, 2016. Plaintiff filed her motion to…
…vested any control in Mr. Epstein “in regard to key facts and subject matter of litigation.” As the Court is well aware from review of emails submitted in camera (and later produced to Plaintiff): o Mr. Epstein and his counsel…
…follows: Ms. Giuffre, in accordance with the Court’s direction at the hearing on April 21, 2016, has submitted documents to the Court for In Camera review. Ms. Giuffre met with the FBI on or about March 17, 2011. Ms…
…subject matter” of the communications. Plaintiff cites three cases from the Southern District of 15 New York, describes them as “controlling precedent” and demands an in camera review of the subject documents. First, Ms. Maxwell’s privilege log satisfies the…
…it was necessary for the rendering of legal advice, I'll 15 review those materials in camera and try to reach a decision. 16 I may need something further after I have looked at them, but I 17 think that…
…and of the outlets to which she distributed them. Indeed, as the Court knows from the documents it reviewed in camera and found were not privileged, Defendant and Dershowitz were regularly communicating regarding how best to attack Ms. Giuffre. Accordingly…