giuffre-maxwell
gov.uscourts.nysd.447706.15.0
29 pg
…Enters, Inc., 209 F.3d 163 (2d Cir. 2000) .............................. 17
Club Valencia Homeowners Ass’n, Inc. v. Valencia Associates, 712 P.2d 1024 (Colo.
App. 1985) ..................................................................................................................... 13
Cohen v. Stevanovich, 772 F.Supp.2d 416,…
giuffre-maxwell
gov.uscourts.nysd.447706.1062.0
7 pg
…of the Reliance
Finally, courts examine the ways in which those from whom discovery is sought – both
parties and non-parties – conducted themselves in reliance on a protective order. For example,
courts consider whether discovery was provided that otherwise could…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…2015, Maxwell again issued a statement,
responding to the allegations made in connection with Giuffre's
Joinder Motion. Maxwell stated that Giuffre's allegations
"against Ghislaine Maxwell are untrue" and that Giuffre's
"claims are obvious lies" (the "January 3…
giuffre-maxwell
gov.uscourts.nysd.447706.1122.0_2
13 pg
…There are at least two
circumstances connected with this litigation that give rise to the USVI’s compelling need.
The first is Jeffrey Epstein’s passing after he was deposed as a fact witness in this action,
but before the…
giuffre-maxwell
gov.uscourts.nysd.447706.1253.0
12 pg
…3d 612 (S.D.N.Y. 2019), is distinguishable. That
case was about the unsealing of materials related to searches conducted by the FBI and in
connection with an investigation. Id. at 617-18. With respect to the non-parties…
giuffre-maxwell
gov.uscourts.nysd.447706.1353.0
6 pg
…23, 2021). In doing so, the Government represented that “[s]uch materials will
be used solely in connection with the above-referenced grand jury investigation.” Id. at 4. Judge
1
The assigned district judge in this case, the Honorable Robert…
giuffre-maxwell
gov.uscourts.nysd.447706.1069.0
25 pg
…agree to continue to abide by it and
7 that --
8 THE COURT: Oh, except that the protective order
9 stipulated that the materials would be used in connection with
10 that lawsuit only.
11 MR. COOPER: I do understand…
giuffre-maxwell
gov.uscourts.nysd.447706.96.0
15 pg
…terms to the collected ESI to locate
documents that may be responsive to Defendant’s far-reaching requests. Despite this, and
despite attempting to have dialogue about collection procedures, Defendant has refused to
discuss her questionable collection processes that yielded…
giuffre-maxwell
gov.uscourts.nysd.447706.977.2
1 pg
…the district court is better suited to
the task. As the Court’s opinion recognizes in connection with the remaining
sealed materials, the district court is better positioned to communicate with the
parties and any nonparties whose privacy interests might…
giuffre-maxwell
gov.uscourts.nysd.447706.968.1
1 pg
…the district court is better suited to
the task. As the Court’s opinion recognizes in connection with the remaining
sealed materials, the district court is better positioned to communicate with the
parties and any nonparties whose privacy interests might…
giuffre-maxwell
gov.uscourts.nysd.447706.1210.0_1
3 pg
…however, reliance on
the protective order does not per se outweigh the public’s right
to access the deposition testimony filed in connection with the
motions in this case. In unsealing the summary judgment record,
the Court of Appeals redacted…
giuffre-maxwell
gov.uscourts.nysd.447706.1312.0
9 pg
…certain documents might be embarrassing, would expose non-
parties to media attention, and could result in some unfortunate association between the non-parties
and Jeffrey Epstein or Ghislaine Maxwell. But as the Court has previously recognized, such
generalized concerns about…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…to non-dispositive motions… ‘is generally somewhat
lower than the presumption applied to material introduced at trial, or in connection with
dispositive motions such as motions for dismissal or summary judgment.’”) (quoting Brown, 929
F.3d at 50).
A…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.16
2 pg
…to wit: that, in the event that this Court
orders that the deposition of Sarah Ransome, which was filed in connection with a motion for a
protective order (ECF No. 701-1), be unsealed and/or de-designated—an action…
giuffre-maxwell
gov.uscourts.nysd.447706.41.5
18 pg
…RWS Document 41-5 Filed 03/04/16 Page 4 of 18
b. persons regularly employed or associated with the attorneys actively
working on this case whose assistance is required by said attorneys in the
preparation for trial, at trial…
giuffre-maxwell
gov.uscourts.nysd.447706.39.1
7 pg
…attorneys actively working on this case;
b. persons regularly employed or associated with the attorneys actively
working on this case whose assistance is required by said attorneys in the
preparation for trial, at trial, or at other proceedings in this…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…and therefore, at most,
begin with a presumption of public access “somewhat lower than the presumption applied to
material introduced at trial, or in connection with dispositive motions such as motions for
dismissal or summary judgment.” Brown v. Maxwell, 929…
giuffre-maxwell
gov.uscourts.nysd.447706.135.0
37 pg
…i red Jaff e , th~n of Co h en & Gresser LLP, to
represent her in connection wlth l ega l matte r s in the United
States a t some indeterminate point in 2009 . Def.'s Deel . of L.A …
giuffre-maxwell
gov.uscourts.nysd.447706.962.0
7 pg
…custody and control. See generally id.
at 7-9.
1. Mr. Dershowitz moved to unseal portions of a brief filed in connection with a motion
to quash, discrete emails filed with the motion, and the manuscript of Ms. Giuffre’s…
giuffre-maxwell
gov.uscourts.nysd.447706.222.0
10 pg
…the Fifth Amendment invocation that counsel for Mr. Epstein (since
at least March 8, 2016) has represented to plaintiff’s counsel would be made by Mr. Epstein in
connection with the Subpoena. See Poe Decl., Exhibits 2, 6 (email correspondence)…
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