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.447706.264.0
3 pg
…ordered as follows:
This matter being subject to a Protective Order, the parties are directed to meet and
confer regarding redactions to this Opinion consistent with that Order. The parties are
further directed to jointly file a proposed redacted version…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.17
12 pg
…30(a)(2)(A)(ii)). “Leave should be granted to
the extent that doing so is consistent with the factors set forth in Rule 26(b)(2), such as ‘whether
the second deposition of the witness would be unnecessarily cumulative…
giuffre-maxwell
gov.uscourts.nysd.447706.995.0
11 pg
…revealed. The law relating to filing
documents under seal is not intended to allow individuals who participated in actionable conduct
to prevent the public from knowing their identity.
Consistent with the general presumption of public access to court documents, the…
giuffre-maxwell
gov.uscourts.nysd.447706.343.0
8 pg
…in her moving brief. While the conduct of Defendant and
Mr. Gow is consistent with the obstructionist tactics Defendant has employed throughout this
litigation, the important point at this stage of the case is to secure Mr. Gow’s testimony…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.33
24 pg
…Maxwell would require an extension of the discovery period ................................ 17
II. STRIKING CLAIMS FOR MEDICAL AND EMOTIONAL DISTRESS DAMAGES IS
CONSISTENT WITH THE PURPOSE OF RULE 37, COMMENSURATE WITH THE
INFORMATION WITHHELD, AND LESS HARSH THAN THE AVAILABLE
DISMISSAL SANCTION..…
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.447706.639.0
2 pg
…of the new anticipated trial date of May 15, 2017.
Accordingly, the parties request that the Court vacate the hearing scheduled for
consistent with the Court's schedule. s
February 23, 2017 in this case to be rescheduled by agreement…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.1_2
24 pg
…Maxwell would require an extension of the discovery period ................................ 17
II. STRIKING CLAIMS FOR MEDICAL AND EMOTIONAL DISTRESS DAMAGES IS
CONSISTENT WITH THE PURPOSE OF RULE 37, COMMENSURATE WITH THE
INFORMATION WITHHELD, AND LESS HARSH THAN THE AVAILABLE
DISMISSAL SANCTION..…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.8
6 pg
…will add to our log. We also located a number of
privileged communications between our client and myself following the onset of litigation in this case which
will not be logged consistent with both parties' agreed to practice. As predicted…
giuffre-maxwell
1320-33
24 pg
…Maxwell would require an extension of the discovery period ................................ 17
II. STRIKING CLAIMS FOR MEDICAL AND EMOTIONAL DISTRESS DAMAGES IS
CONSISTENT WITH THE PURPOSE OF RULE 37, COMMENSURATE WITH THE
INFORMATION WITHHELD, AND LESS HARSH THAN THE AVAILABLE
DISMISSAL SANCTION..…
giuffre-maxwell
gov.uscourts.nysd.447706.1351.0
32 pg
…and the case is REMANDED to the district court
for individualized review of materials consistent with this Court’s opinion.
For the Court:
Catherine O’Hagan Wolfe,
…
giuffre-maxwell
gov.uscourts.nysd.447706.1129.0_5
2 pg
…and difficult to communicate with) is
still considering whether to seek any further emergency appellate remedies and/or to provide
this Court additional information to the extent consistent with other courts’ rulings that might
impact the release of these materials…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.30
6 pg
…will add to our log. We also located a number of
privileged communications between our client and myself following the onset of litigation in this case which
will not be logged consistent with both parties' agreed to practice. As predicted…
giuffre-maxwell
gov.uscourts.nysd.447706.961.0
9 pg
…Ms. Giuffre demonstrates below, Courts within the
Second Circuit consistently hold that document destruction obligations under a protective order
are not triggered until the completion of all the appellate proceedings. While many aspects of
this case are obviously concluded, issues…
giuffre-maxwell
gov.uscourts.nysd.447706.231.0
23 pg
…Maxwell would require an extension of the discovery period ................................ 17
II. STRIKING CLAIMS FOR MEDICAL AND EMOTIONAL DISTRESS DAMAGES IS
CONSISTENT WITH THE PURPOSE OF RULE 37, COMMENSURATE WITH THE
INFORMATION WITHHELD, AND LESS HARSH THAN THE AVAILABLE
DISMISSAL SANCTION..…
giuffre-maxwell
gov.uscourts.nysd.447706.1227.0
2 pg
…1143 at 2. Doe did not object to proceeding this way
when Plaintiff filed her letter nine months ago, and the Original Parties have consistently relied on
this understanding, which has never been challenged or otherwise contradicted.
Finally, even if…
giuffre-maxwell
gov.uscourts.nysd.447706.1214.0
7 pg
…1
ARGUMENT
In the Objections, Ms. Maxwell concedes that this Court has consistently found that the
presumption of public access outweighs Ms. Maxwell’s asserted countervailing interests, and she
fails to offer any additional arguments to warrant the continued sealing…
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.447706.1328.20
14 pg
…A (GM00784-
00801). Consistent with Florida law, the records were redacted by the Palm
Beach County Sheriff’s Office for the identities and other identifying information
of all juveniles as well as Plaintiff’s parents.
x January 1998 – In contradiction…
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