…District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S MOTION TO MAINTAIN CONFIDENTIALITY DESIGNATION Plaintiff Virginia Giuffre, by and through her undersigned couns…
…is that the public interest might otherwise be harmed if extremely sensitive material were to lose this special shield of confidentiality.2 Whether the privilege applies is determined by balancing the needs of the plaintiffs against the needs of the…
…case. In unsealing the summary judgment record, the Court of Appeals redacted “deposition responses concerning intimate matters where the questions were likely only permitted— and the responses only compelled—because of a strong expectation of continued confidentiality.” Brown v. Maxwell…
…Id. at 2. As this Court knows, the Second Circuit spoke directly to the issues of confidentiality and unsealing of documents in this case and specifically vacated two of the three decisions cited by Maxwell. Brown v. Maxwell, 929 F…
…the hundreds of interested Non-Parties together with Ms. Maxwell have every right and reason to expect that the promises of confidentiality afforded by a Protective Order, to which Plaintiff and 2 Case 1:15-cv-07433-LAP Document…
…2017, this Court ordered: “[A]ll documents, materials, and information subject to the Protective Order must be returned to the party who designated its confidentiality as of the date this action was dismissed.” Id. 2 (emphasis supplied). Ms. Giuffre and…
…that a non-party cannot seek to overturn the protective order as follows: “The Protective Order states that parties can object to the confidentiality designations: “A party may object to the designation of particular CONFIDENTIAL INFORMATION by giving written notice…
…Intervenor’s June 21, 2017 letter and its attachments, and remove the confidentiality designation from several related emails and attachments that the parties previously designated confidential (RANSOME_000273-557) (“the Emails”). The Emails will demonstrate that Ms. Ransome’s inflammatory…
…sealed in Maxwell.” DE 233, at 2. The Court’s revised language underscored that “the parties may only agree to remove confidentiality designations for Ms. Giuffre’s personal documents” from Maxwell, “i.e., those bearing her bates stamp in Maxwell…
…See May 18, 2016 letter from J. Pagliuca ("Your email does not provide any good faith basis for the [confidentiality] assertion, likely because there is none."). I disagree. Your latest produc6on includes a police report detailing the rape of a…
…that this is fishing with a drift net. We decline your request to engage in this exercise. Regarding redacted police reports that plaintiff designated “confidential”: We objected to plaintiff’s confidentiality designation, and plaintiff failed to file a motion in…
…by its redactions, implicitly held that the deposition contained “responses concerning intimate matters where the questions were likely only permitted – and the responses only compelled – because of a strong expectation of continued confidentiality.” See Resp. at 5 (“this court should…
…for the sake of efficiency, re-produced in the Dershowitz case her document productions from the Maxwell case with whatever confidentiality designations were originally applied in the Maxwell case. Recognizing that some documents which Ms. Giuffre designated as confidential in…
…but a confidentiality order shall be entered. Regarding the deposition: The depo shall be limited to 4 hours without prejudice to request additional time in the future. The Defendant can be present at the depo. The depo will be taken…
…been rejected by this Court numerous times. The Second Circuit has held that “the mere existence of a confidentiality order says nothing about whether complete reliance on the order to avoid disclosure 1 Again, Intervenors do not have access to…
…and 23. The Motion is denied as to the remaining Requests. b. A Confidentiality Order shall be entered. c. The deposition of Jane Doe No. 3 shall be limited to 4 hours without prejudice to request for add itional time…
…an Illegitimate Purpose Which Disqualifies Him from Relief.................................................................... 22 4. Under This Court’s Order, Non-Parties Cannot Challenge Confidentiality Designations and Dershowitz has Already A…
… Specifically, certain materials may both (1) lack confidentiality designations made pursuant to the Protective Order and (2) be filed under seal in the Maxwell litigation. To the extent that the materials mention nonparties to the Maxwell action and remain under…
…fairly obvious that this is fishing with a drift net. We decline your request to engage in this exercise. Regarding redacted police reports that plaintiff designated “confidential”: We objected to plaintiff’s confidentiality designation, and plaintiff failed to file a …
… PROCEDURAL HISTORY On February 12, 2016 Ms. Maxwell served her First Set of Discovery Requests on Plaintiff. Request Number 19 requested “Any Document reflecting a confidentiality agreement, settlement agreement, or any contractual agreement of any kind, between You …
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