…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…
…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…
…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 ...........................................…
…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 requests that this Court maintain the confidentiality designations over these police reports and direct the Defendant to disclose all the recipients of the 1 Case 1:15-cv-07433-LAP Document 1199-1 Filed 01/27/21 Page…
…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…
…from when she was a child, some of them concerning her being raped when only 14 years. Defendant’s challenge to Ms. Giuffre’s confidentiality designation is without merit, and it is for improper purposes. Therefore, it should be denied…
…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…
…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…
…them from when she was a child, some of them concerning her being raped when only 14 years. Defendant’s challenge to Ms. Giuffre’s confidentiality designation is without merit, and it is for improper purposes. Therefore, it should - be…
…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…
…and Common Interest Privilege Are Appropriate, And Defendant’s Argument On This Point Is Meritless .........................................11 3. Ms. Giuffre Is Not Withholding Information Based on Confidentiality, Proprietary Rights, Or Their Sensitive Nature ...........…
…and testimony in Maxwell reasonably relied on the Maxwell protective order, whose promises of confidentiality “functioned as a powerful mechanism for inducing parties to provide discovery in a contentious litigation.” (Id. at 11-12.) S…
…In should be noted that the entire deposition of Epstein is confidential, having been placed under the confidentiality order that exists in the case. II. LEGAL ARGUMENT The parties agree this case should be placed under seal because of the…
…Even if so, and putting aside waiver of confidentiality from this disclosure, Epstein’s invocation of his Fifth Amendment 1 Case 1:15-cv-07433-LAP Document 1122 Filed 09/24/20 Page 3 of 13 to refuse to…
…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…
…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…
…with the victims about the NPA, the U.S. Attorney’s Office and Epstein agreed to a “confidentiality” provision in the Agreement barring its disclosure to anyone—including Epstein’s victims. As a consequence, the victims were not told about…
… 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…