giuffre-maxwell
gov.uscourts.nysd.447706.1335.0
1 pg
…following conferral with
Defendant, Plaintiff files this set of documents ordered unsealed. This filing also excludes
documents pertaining to Does 105 (see December 28, 2023, Email Correspondence with
Chambers), 107, and 110 (see ECF No. 1319), while the Court’s…
giuffre-maxwell
gov.uscourts.nysd.447706.1154.0_5
3 pg
…various
issues surrounding the unsealing protocol.
In the final paragraph of her November 10, 2020 correspondence, Plaintiff asserts her
belief that the Court will consider in this current round of unsealing not only whether to
release Doe 1 and 2…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.12_1
4 pg
…Information.
3. Attached hereto as Exhibit 1 is a true and correct copy of July 29, 2016,
Correspondence from Ty Gee.
4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of Excerpt from
April 22, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.0
1 pg
…The filing of these documents
ordered unsealed will be done on a rolling basis until completed. This filing also excludes
documents pertaining to Does 105 (see December 28, 2023, Email Correspondence with
Chambers), 107, and 110 (see ECF No. 1319)…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.4_1
29 pg
…TABLE OF AUTHORITIES ....................................................................................................... ii
CERTIFICATE OF CONFERRAL ............................................................................................ 1
INTRODUCTION.......................................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.0
1 pg
…The filing of these documents
ordered unsealed will be done on a rolling basis until completed. This filing also excludes
documents pertaining to Does 105 (see December 28, 2023, Email Correspondence with
Chambers), 107, and 110 (see ECF No. 1319)…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.14
4 pg
…as Sealed Exhibit 1 is a true and correct copy of February 9,
2017, Correspondence from Jack Goldberger.
4.
-
Attached hereto as Sealed Exhibit 2 is a true and correct copy of February 8,
2017, Affidavit of Anna Intriago.
5…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.0
1 pg
…The filing of these documents
ordered unsealed will be done on a rolling basis until completed. This filing also excludes
documents pertaining to Does 105 (see December 28, 2023, Email Correspondence with
Chambers), 107, and 110 (see ECF No. 1319)…
giuffre-maxwell
gov.uscourts.nysd.447706.164.0
29 pg
…TABLE OF AUTHORITIES ....................................................................................................... ii
CERTIFICATE OF CONFERRAL ............................................................................................ 1
INTRODUCTION.......................................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.338.1
4 pg
…Instruction Based on New Information.
3. Attached hereto as Exhibit 1 is a true and correct copy of July 29, 2016,
Correspondence from Ty Gee.
4. Attached hereto as Sealed Exhibit 2
5. Attached hereto as Sealed Exhibit 3 i
…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.31
2 pg
…Opposition to Defendant’s Motion To Reopen Plaintiff’s Deposition.
2. Attached as Exhibit D (filed under seal) is a true and correct copy of
correspondence between Plaintiff and literary agent Marianne Strong dated February 19, 2014
and February 21…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.0
1 pg
…The filing of these documents
ordered unsealed will be done on a rolling basis until completed. This filing also excludes
documents pertaining to Does 105 (see December 28, 2023, Email Correspondence with
Chambers), 107, and 110 (see ECF No. 1319)…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.20
4 pg
…Information.
3. Attached hereto as Exhibit 1 is a true and correct copy of July 29, 2016,
Correspondence from Ty Gee.
4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of Excerpt from
April 22, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.0
1 pg
…The filing of these documents
ordered unsealed will be done on a rolling basis until completed. This filing also excludes
documents pertaining to Does 105 (see December 28, 2023, Email Correspondence with
Chambers), 107, and 110 (see ECF No. 1319)…
giuffre-maxwell
1320
1 pg
…The filing of these documents
ordered unsealed will be done on a rolling basis until completed. This filing also excludes
documents pertaining to Does 105 (see December 28, 2023, Email Correspondence with
Chambers), 107, and 110 (see ECF No. 1319)…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.32
4 pg
…3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of November 10,
2015, Correspondence from Ross Gow to Ghislaine Maxwell.
4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of January 8…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.0
1 pg
…The filing of these documents
ordered unsealed will be done on a rolling basis until completed. This filing also excludes
documents pertaining to Does 105 (see December 28, 2023, Email Correspondence with
Chambers), 107, and 110 (see ECF No. 1319)…
giuffre-maxwell
gov.uscourts.nysd.447706.165.1
6 pg
…on Plaintiff that outweighs its benefit. Therefore,
Plaintiff has employed categorical logging pursuant to Local Civil
Virginia Giuffre, Brad …
giuffre-maxwell
gov.uscourts.nysd.447706.156.7
6 pg
…on Plaintiff that outweighs its
benefit. Therefore, Plaintiff has employed
categorical logging pursuant to Local Civil Rule
…
giuffre-maxwell
gov.uscourts.nysd.447706.117.0
2 pg
…action. I respectfully submit this declaration in
support of Defendant’s Opposition to Plaintiff’s Motion for Forensic Examination.
2. Attached as Exhibit A are true and correct copies of correspondence between
counsel for Ms. Maxwell and counsel for Ms…