giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…be looking over her shoulder—that is, for reporters lurking in the
bushes, ready to pounce with voice recorders and cameras in hand. In recent months,
journalists have searched high and low for Maxwell, who had already been
maintaining a…
giuffre-maxwell
gov.uscourts.nysd.447706.148.0
9 pg
…9
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
--------------------------------------------------X
......
.........................................
VIRGINIA L. GIUFFRE,
Pla…
giuffre-maxwell
gov.uscourts.nysd.447706.1087.0
4 pg
…no. 1084.)
Prior to receiving Ms. Maxwell’s latest last-minute request,
the Court conducted an in camera review of Plaintiff Virginia
Giuffre’s proposed redactions to the materials, which are
described in Ms. Giuffre’s letter dated July 29…
giuffre-maxwell
gov.uscourts.nysd.447706.1136.0_5
2 pg
…MAXWELL,
Defendant.
LORETTA A. PRESKA, Senior United States District Judge:
The Court has reviewed the parties’ proposed redactions that
were provided to the Court for in camera review on the evening of
October 21, 2020. The Court has approved Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1318.0
3 pg
…2023, submit to the Court for in
camera review an affidavit supporting her assertion that she
faces a risk of physical harm in her country of residence and
providing detail concerning the hate mail she received. Doe 107's
counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.991.1
48 pg
…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
…
giuffre-maxwell
gov.uscourts.nysd.447706.1100.0
16 pg
…modification of the Protective Order
in the Criminal Action from Judge Nathan forthwith to permit sharing the information with
this Court, ex parte and in camera if necessary, and with the Second Circuit (likewise under
seal if necessary).
Case…
giuffre-maxwell
gov.uscourts.nysd.447706.1317.0
3 pg
…2023, submit to the Court for in
camera review an affidavit supporting her assertion that she
faces a risk of physical harm in her country of residence and
providing detail concerning the hate mail she received. Doe 107's
counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.986.0
60 pg
…# 2 Exhibit, # 3 Exhibit)
Motion to Compel
NOTICE of In Camera Submission re: 134 Order.
05/04/2016 141 – Judicial Document Document filed by Virginia L. Giuffre.
(In Camera Materials)
…
giuffre-maxwell
gov.uscourts.nysd.447706.1099.0
4 pg
…Dkt. 1087
at 2–3. Nor did Maxwell’s counsel offer to provide the Court with a competing set of proposed
redactions for in camera review until the afternoon of the Court-ordered deadline to unseal. Even
then, Maxwell’s…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…That's troubling as well because we went through
2 litigation in this case about our access to alleged
3 public-interest privileged documents that were not turned over
4 to us but were submitted in camera to the Court…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…to the world that she “cried rape,”13 and to
humiliate her family (including three minor children) by publicizing she was the victim of
domestic abuse in 2015. As the Court saw during its in camera review, Defendant and Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.33
24 pg
…ordered to produce all documents relating to alleged law enforcement
inquiries other than Plaintiff’s own statements (which would be provided for in camera review),
she simply provided all documents relating to alleged law enforcement inquires for in camera
review…
giuffre-maxwell
gov.uscourts.nysd.447706.949.0
31 pg
…on the record. I'm not asking this Court to do
23 that, but in Florida where I practice more, most of the time,
24 judges routinely allow me to participate in in-camera
25 examinations -- videos, documents, hearings, testimony …
giuffre-maxwell
gov.uscourts.nysd.447706.1327.9
21 pg
…April 21, 2016 . ?laintiff was directed to submit the
relevant materials for in camera review. Plaintiff did so on
April 28 1 2016.
Plaintiff filed her motion to compel Defendant to answer
deposition questions on May 5, 2016. Oral argument…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.31
13 pg
…public. At
the very least, the Court should conduct an in camera review of any joint defense agreements
that exist to determine their relevance to both the defamation claim and the multiple affirmative
defenses offered by Defendant. See Steuben Foods…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.1_2
24 pg
…ordered to produce all documents relating to alleged law enforcement
inquiries other than Plaintiff’s own statements (which would be provided for in camera review),
she simply provided all documents relating to alleged law enforcement inquires for in camera
review…
giuffre-maxwell
gov.uscourts.nysd.447706.63.0
22 pg
…
Plaintiff’s gamesmanship is clear: she wants to get Ms. Maxwell on a videotaped
deposition camera, show her documents that she has not had a chance to review either because
they were not produced or because they were produced so…
giuffre-maxwell
gov.uscourts.nysd.447706.1049.0
91 pg
…Privilege
57‐1:3 Exhibits 1‐3 3.14.16
Defendant's Notice of
Submission of Declaration in
Support of Defendant's In
Camera Submission in
77 3.31.16
Opposition to Plaintiffs Motion
to Compel the Production of
Documents…
giuffre-maxwell
gov.uscourts.nysd.447706.849.0
94 pg
…seems to be
6 cumulative. It's also prejudicial, and it also denies my
7 ability to confront and cross-examine a witness who is
8 appearing for the camera and acting. So that's Kliman.
9 Jansen, your Honor…