giuffre-maxwell
gov.uscourts.nysd.447706.648.0
4 pg
…designations.
May 4, 2107, Pre-trial Conference to address any outstanding issues including
confidentiality.
WHEREFORE, the parties request that the Court adopt the proposed schedule and
modify the Court' s Order of October 3, 2016 to reflect the above deadlines…
giuffre-maxwell
gov.uscourts.nysd.447706.40.0
8 pg
…because Ms. Giuffre
corrected some typographical and spelling issues.
2
confidentiality designations of that type of discovery would wrongfully allow the
abuser to hide behind a claim of confidentiality.
Purposes and Limitations: Ms. Giuffre’s proposed revisions include…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…C. All Documents Were Redacted Appropriately By the Law Enforcement Agencies ........... 8
II. PLAINTIFF HAS WAIVED ANY ARGUMENT AS TO CONFIDENTIALITY ................ 9
A. Plaintiff Failed to Timely Move this Court to Uphold Her Designation of the Documents
as Confidential ...........................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…Which
Disqualifies Him from Relief.................................................................... 22
4. Under This Court’s Order, Non-Parties Cannot Challenge Confidentiality
Designations and Dershowitz has Already Agreed to be Bound by the…
giuffre-maxwell
gov.uscourts.nysd.447706.1210.0_1
3 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.15
11 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.363.14
2 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1083.0
3 pg
…pages ) but not in others (e.g., page ).
Both of these two alleged victims are represented by counsel and sought confidentiality for
their depositions; neither has yet been afforded notice or an opportunity to be heard with
respect to this…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.33
3 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.22
31 pg
…Which
Disqualifies Him from Relief.................................................................... 22
4. Under This Court’s Order, Non-Parties Cannot Challenge Confidentiality
Designations and Dershowitz has Already Agreed to be Bound by the…
giuffre-maxwell
gov.uscourts.nysd.447706.442.1
3 pg
…9 I think it's more like listing witnesses. So I would say that
10 the plaintiff should supply all residences.
11 The Dershowitz deposition will be produced under the
12 confidentiality provision. As I read what I've been…
giuffre-maxwell
gov.uscourts.nysd.447706.140.3
4 pg
… 42:178. Public-interest privilege
West’s Key Number Digest
West’s Key Number Digest, Privileged Communications and Confidentiality 357
A public-interest privilege, which permits appropriate parties to protect information from ordinary disclosure, inheres in
certain co…
giuffre-maxwell
gov.uscourts.nysd.447706.992.0
5 pg
…as here, the disputed documents are
filed in support of or in opposition to a discovery motion other than a motion as to the
discoverability or confidentiality of the disputed documents themselves, they are properly
Case 1:15-cv…
giuffre-maxwell
gov.uscourts.nysd.447706.944.0
11 pg
…allowed the parties to provide discovery on highly private and
sensitive subjects that could not be disclosed to the public without a further order of this Court.
The Protective Order “provided confidentiality for information the parties determine would
‘improperly annoy…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.9
18 pg
…and redacting all substantive references to them, pending disposition of this application.
Although I have erred on the side of strict confidentiality to avoid any semblance of violating the
Court’s Protective Order, I of course do not believe that…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.6_1
14 pg
…C. All Documents Were Redacted Appropriately By the Law Enforcement Agencies ........... 8
II. PLAINTIFF HAS WAIVED ANY ARGUMENT AS TO CONFIDENTIALITY ................ 9
A. Plaintiff Failed to Timely Move this Court to Uphold Her Designation of the Documents
as Confidential ...........................................…
giuffre-maxwell
gov.uscourts.nysd.447706.57.2
30 pg
…I shall not
distinguish between those two companies for the purposes of this judgment (because it is
not necessary to do so) and shall treat all relevant copyright and confidentiality rights as
being vested in what I will call "USP"…
giuffre-maxwell
gov.uscourts.nysd.447706.1191.0_1
3 pg
…v. Sprint Corp., 407 F.3d 560, 562 (2d Cir. 2005) (“It is
presumptively unfair for courts to modify protective orders which assure confidentiality and
upon which the parties have reasonably relied.”); see also Martindell v. Int’l Tel. & Tel…
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