giuffre-maxwell
gov.uscourts.nysd.447706.1069.0
25 pg
…while we do not. And
15 with respect, I understand how that seems to have come about by
16 a coincidence or perhaps an intentional representation in both
17 cases, but that situation is unfair and inequitable, and I
18…
giuffre-maxwell
gov.uscourts.nysd.447706.589.0
24 pg
…which is currently pending in the Second Circuit. It is our
understanding that Dershowitz will shortly be moving to dismiss his appeal.
1
This seeming “concidence” is less remarkable given the strong ties shared by Dershowitz
and Cernovich. Cernovich…
giuffre-maxwell
gov.uscourts.nysd.447706.1105.0
8 pg
…modification. In contrast, there are compelling reasons to
maintain the Protective Order, the modification of which is “perilous for multiple reasons,”
including that such modifications “undermine confidence in protective orders” and may well
subject individuals to “annoyance, embarrassment, oppression, or…
giuffre-maxwell
gov.uscourts.nysd.447706.442.1
3 pg
…the
12 confidentiality provision. As I read what I've been given,
13 it's to be held in confidence and it will remain in confidence,
14 but it will be produced.
15 Yes, the tax returns should be produced…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…the
12 confidentiality provision. As I read what I've been given,
13 it's to be held in confidence and it will remain in confidence,
14 but it will be produced.
15 Yes, the tax returns should be produced…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…II”) (“The
presumption of access is based on the need for federal courts, although independent—indeed,
particularly because they are independent—to have a measure of accountability and for the
public to have confidence in the administration of justice.”). Indeed…
giuffre-maxwell
gov.uscourts.nysd.447706.1008.0
5 pg
…were ultimately not ruled upon contradicts the purpose of public access to judicial records: to
ensure “that the federal courts ‘have a measure of accountability’ and so that the public may ‘have
confidence in the administration of justice.’” Bernstein v…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…She has some amazing names which she can share with you in
confidence and I think she also has a human interest story that
2
The relevant excerpts of the Requested Documents are reproduced herein without any alterations or corrections…
giuffre-maxwell
gov.uscourts.nysd.447706.1242.0
9 pg
…although
independent—indeed, particularly because they are independent—to have a measure of
accountability and for the public to have confidence in the administration of justice.”). Although
the Does cite to Amodeo to support their assertion that materials concerning children…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…deposition, were created or
4 obtained by Ms. Churcher in the course of her news-gathering
5 activities, and much of the information sought was communicated
6 in confidence, as well. So under the New York State Shield
7 Law…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.3
21 pg
…1987) (privilege waived where client encouraged lawyer to write a
9
Case 1:15-cv-07433-LAP Document 1332-3 Filed 01/08/24 Page 14 of 21
book about legal representation and reveal other confidences on television program)…
giuffre-maxwell
gov.uscourts.nysd.447706.503.0
21 pg
…3d 300, 310, 3 N.E.3d 694 (2013).
Accordingly, the New York Shield Law provides protection of
information "obtained or received in confidence" by a reporter,
as well as for the identity of a confidential source. N. Y. Civ…
giuffre-maxwell
gov.uscourts.nysd.447706.1014.0
3 pg
…public could have had access, had they only acted faster to enforce their rights, is found
nowhere in the case law and cannot possibly serve the public interest in promoting “confidence in
the conscientiousness, reasonableness, or honesty of judicial proceedings…
giuffre-maxwell
gov.uscourts.nysd.447706.68.0
17 pg
…This is because ‘in libel any language published of a person that
tends to degrade him or to bring him into ill repute, or to destroy the confidence of his neighbors
in his integrity, or to cause others like injury…
giuffre-maxwell
gov.uscourts.nysd.447706.364.0
32 pg
…need for federal courts, although independent—indeed, particularly because
they are independent—to have a measure of accountability and for the public to have confidence
in the administration of justice,” United States v. Amodeo (Amodeo II), 71 F.3d 1044…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…need
for federal courts, although independent- indeed, particularly
because they are independent- to have a measure of accountabili ty
and for the public to have confidence in the administratio n of
justice." United States v. Amodeo, 71 F.3d 1044…
giuffre-maxwell
gov.uscourts.nysd.447706.946.0_1
14 pg
…with critical
views of their work and deters arbitrary judicial behavior. Without
monitoring, moreover, the public could have no confidence in the
conscientiousness, reasonableness, or honesty of judicial
proceedings. Such monitoring is not possible without access to
…
giuffre-maxwell
gov.uscourts.nysd.447706.363.13
15 pg
…confidential information. That protection is not limited to the identities of
confidential sources, but any information conveyed in confidence—even if that source is not
anonymous or also conveyed non-confidential information. See Section 79-h(b).
In sum, Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.406.0
31 pg
…II”) (“The
presumption of access is based on the need for federal courts, although independent—indeed,
particularly because they are independent—to have a measure of accountability and for the
public to have confidence in the administration of justice.”). Indeed…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.2
70 pg
…speak is nine am her time tomorrow (Monday your time) .
Virginia would prefer me to be present when you initiate communication with
her. We both realize that any such communication must be in confidence. I
will be there for support…
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