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.447706.1328.41
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.447706.1218.14
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.447706.364.0
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.447706.406.0
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…
giuffre-maxwell
gov.uscourts.nysd.447706.135.0
37 pg
… . _,.
. .: . . ·-.. ,. : -: .;. -~-
confidence between sol i citor and client to enable the latter to
receive necessaty · legal"' advice.''!) ·• with People · v. · Mitchell, 58
·' -…
giuffre-maxwell
gov.uscourts.nysd.447706.604.0
11 pg
…s plight. However, when the Article III power
of the Court is invoked, “access to testimony and documents” makes monitoring necessary to
instill in the public “confidence in the conscientiousness, reasonableness, or honesty of judicial
proceedings.” United States v. Amodeo…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.13
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.447706.1218.22
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.447706.56.0
14 pg
…any evidence, such as a Non-Disclosure Agreement, that
expressly places Ross Gow under an obligation of confidence in respect to information received
by him relating to legal advice/litigation. In absence of any express obligation of confidentiality,
Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.936.0
21 pg
…The law provides the public with the presumption of access in
order to hold our legal instutitions accountable and to maintain confidence that they will protect
the most vulnerable in our society.
THE OVERBROAD SEALING ORDER AND PRIOR ATTEMPTS TO…
giuffre-maxwell
gov.uscourts.nysd.447706.33.0
19 pg
…of the attorney-client relationship, a claim
resting on the common interest rule requires a showing that the communication in
question was given in confidence and that the client reasonably understood it to be so
given. And once the party…
giuffre-maxwell
gov.uscourts.nysd.447706.155.0
15 pg
…639 (2d Cir. 1962) (“Insofar as the
papers include pre-existing documents and financial records not prepared by [the party] for the
purpose of communicating with their lawyers in confidence, their contents have acquired no
special protection from the simple…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.6
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.447706.1349.0
31 pg
…F.3d at 119. The presumption of public access is based on the need for
independent federal courts “to have a measure of accountability and for the
public to have confidence in the administration of justice.” Id. (quoting
United States…
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