giuffre-maxwell
gov.uscourts.nysd.447706.1285.0
6 pg
…Doe 171 respectfully requests that this Court provide modest relief from its
ore tenus unsealing order to remain consistent with its treatment of other Non-Party
Does who continue to experience trauma as a result of the events that are…
giuffre-maxwell
gov.uscourts.nysd.447706.1046.0
3 pg
…unsealing process moves forward efficiently
and swiftly, and is consistent with the goal of satisfying the public’s right of access to the
information it seeks in as expeditious a manner as possible. Plaintiff understands that Maxwell
will argue that…
giuffre-maxwell
gov.uscourts.nysd.447706.1286.0
6 pg
…Doe 171 respectfully requests that this Court provide modest relief from its
ore tenus unsealing order to remain consistent with its treatment of other Non-Party
Does who continue to experience trauma as a result of the events that are…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…ofPage
01/21/2015 41 2 of 40
sworn affidavit (attached as Exhibit 1) that all her allegations are true – an affidavit consistent
with compelling corroborating evidence.
BACKGROUND AND COURSE OF PROCEEDINGS
Because this case …
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…respectfully write to ask this Court to protect those non-party
interests; a request that is consistent with long-standing Circuit precedent establishing that this
responsibility “rests heavily upon the shoulders” of the district court. In re New York Times…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…make
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 132-1 Filed 05/01/16 Page 16 of 31
15
G4LMGIUC
1 her story consistent with her previous stories. She has
2…
giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…There, the court recognized that a non-party’s privacy interest
should be protected “if this can be done in a manner consistent with the public’s reasonable interest
in access to evidence relating to Plaintiffs’ equal protection claim.” Id…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…which is why courts who have looked
14 at this issue have consistently rejected these broad subpoenas.
15 Defendants know that they are not entitled to every
16 single personal email plaintiff has ever sent or ever received
17 in…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.40
30 pg
…make
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 1218-40 Filed 07/15/21 Page 16 of 30
15
G4LMGIUC
1 her story consistent with her previous stories. …
giuffre-maxwell
gov.uscourts.nysd.447706.235.1
31 pg
…make
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 235-1 Filed 06/21/16 Page 16 of 31
15
G4LMGIUC
1 her story consistent with her previous stories. …
giuffre-maxwell
gov.uscourts.nysd.447706.136.0_2
29 pg
…make
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
G4LMGIUC
Case 1:15-cv-07433-LAP Document 136 Filed 05/03/16 Page 15 of 29 15
1 her story consistent with her previous stories. She has
2 claimed…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…including one named “Virginia.” Id. at 21. It is
anticipated that he will testify consistently with that previous testimony.
3
As explained above, as of today, Defendant’s counsel sent an email refusing to attend this deposition set
for Tuesday…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…including one named “Virginia.” Id. at 21. It is
anticipated that he will testify consistently with that previous testimony.
3
As explained above, as of today, Defendant’s counsel sent an email refusing to attend this deposition set
for Tuesday…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…including one named "Virginia." Id. at 21. It is
anticipated that he will testify consistently with that previous testimony.
3
As explained above, as of today, Defendant's coW1sel sent an email refusing to attend this deposition set
for Tuesday…
giuffre-maxwell
1320-10
28 pg
…including one named “Virginia.” Id. at 21. It is
anticipated that he will testify consistently with that previous testimony.
3
As explained above, as of today, Defendant’s counsel sent an email refusing to attend this deposition set
for Tuesday…
giuffre-maxwell
gov.uscourts.nysd.447706.172.0
28 pg
…including one named “Virginia.” Id. at 21. It is
anticipated that he will testify consistently with that previous testimony.
3
As explained above, as of today, Defendant’s counsel sent an email refusing to attend this deposition set
for Tuesday…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.6
10 pg
…p. 108-111.
Defendant’s deposition consisted almost entirely of “I don’t recalls” or “I refuse to answer that
question”1 and also included a physical outburst that knocked the court reporter’s computer off
the conference room table…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.10_2
10 pg
…2016 De osition of Defendant at p. 108-11 1.
Defendant's deP.osition consisted almost entirelY. of "I don't recalls" or "I refuse to answer tha
uestion" 1 and also included a hy:sical outburst that knocked the…
giuffre-maxwell
1320-6
10 pg
…p. 108-111.
Defendant’s deposition consisted almost entirely of “I don’t recalls” or “I refuse to answer that
question”1 and also included a physical outburst that knocked the court reporter’s computer off
the conference room table…
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