giuffre-maxwell
gov.uscourts.nysd.447706.731.0
3 pg
…foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the
foregoing document is being served to all parties of record via transmission of the Electronic
Court Filing System generated by CM/ECF…
giuffre-maxwell
gov.uscourts.nysd.447706.363.0
18 pg
…2015, Ms. Giuffre’s attorneys—two of the same
lawyers who represent her in this case—alleged in court filings that I had had sex with Ms.
Giuffre on numerous occasions while she was a minor, including in Florida, on…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.9
18 pg
…2015, Ms. Giuffre’s attorneys—two of the same
lawyers who represent her in this case—alleged in court filings that I had had sex with Ms.
Giuffre on numerous occasions while she was a minor, including in Florida, on…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…of
sexual misconduct against Professor Dershowitz—which were lodged by Ms. Giuffre in public
court filings and repeated worldwide in the press—are nothing more than a recent fabrication, a
made up story designed to increase commercial interest in Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.364.0
32 pg
…¶ 16. In late 2014 and early 2015, Ms.
Giuffre’s lawyers alleged in public court filings in the CVRA Action that Mr. Dershowitz had
had sex with Ms. Giuffre on numerous occasions while she was a minor, including in Florida…
giuffre-maxwell
gov.uscourts.nysd.447706.408.0
13 pg
…foregoing
document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing
document is being served to all parties of record via transmission of the Electronic Court Filing
System generated by CM/ECF…
giuffre-maxwell
gov.uscourts.nysd.447706.589.0
24 pg
…substantially the same relief.
Proposed Intervenor and purported “journalist” Michael Cernovich requests that this
Court grant him intervenor status for the purpose of unsealing and publishing a single filing from
the above-captioned case: Defendant’s Motion for Summary Judgment…
giuffre-maxwell
gov.uscourts.nysd.447706.363.5
6 pg
…al.
COURT USE ONLY
v.
Case Number:
Defendant(s)/Respondent(s): Dershowitz
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.5
3 pg
…foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the
foregoing document is being served to all parties of record via transmission of the Electronic
Court Filing System generated by CM/ECF…
giuffre-maxwell
gov.uscourts.nysd.447706.107.0
4 pg
…Doc. # 88.
Subsequent to the filing of the Objections, Ms. Maxwell obtained a statement issued by
Mr. Cassell and Mr. Edwards related to Edwards and Cassell v. Dershowitz, 15-000072, pending
in Ciruit Court in Broward County Florida, in which…
giuffre-maxwell
gov.uscourts.nysd.447706.104.0
4 pg
…Doc. # 88.
Subsequent to the filing of the Objections, Ms. Maxwell obtained a statement issued by
Mr. Cassell and Mr. Edwards related to Edwards and Cassell v. Dershowitz, 15-000072, pending
in Ciruit Court in Broward County Florida, in which…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…Maxwell requests the Court enforce the Protective Order, deny
Plaintiff’s motion to make publicly available police reports “Confidential” under the terms of the
Protective Order in this case, and award attorneys’ fees and costs associated with the filing of
…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.4_1
29 pg
…when the conversation was
sent to the press, and used in later court filings, Plaintiff did nothing to stop the publication of this privileged
10
Case 1:15-cv-07433-LAP Document 1090-4 Filed 07/30/20 Page…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.50
15 pg
…Dep’t 2000) (“An
essential prerequisite to legal protection against the misappropriation of a trade secret is the
element of secrecy.”). Nor would unsealing a public court filing jeopardize any copyright
protections, assuming any apply to the Manuscript at all…
giuffre-maxwell
gov.uscourts.nysd.447706.962.0
7 pg
…position. They argued that the
pending appeals relating to judicial filings in the Court’s possession justified their continued
refusal to destroy confidential documents in the parties’ possession.
Regardless Ms. Giuffre’s attorneys’ “estoppel” argument is as useless as their…
giuffre-maxwell
gov.uscourts.nysd.447706.637.0
12 pg
…2007 WL 2413033, at **1–2 (D.Me. Aug. 21, 2007) (noting
party's concession of waiver of attorney-client privilege when party submitted privileged email
communications as an exhibit to court filing); Malkovich v. Best Buy Enter. Servs., Inc.…
giuffre-maxwell
gov.uscourts.nysd.447706.978.0
27 pg
…their statements of undisputed facts, and
incorporated exhibits; and (2) court filings made in the course of the
discovery process and with respect to motions in limine. In this
Opinion, we explain that our law requires the unsealing of the…
giuffre-maxwell
gov.uscourts.nysd.447706.936.0
21 pg
…ongoing investigation, the Miami Herald has sought to access public
court filings that will shed light on the scope of Epstein's crimes and address serious questions
about whether there was any undue influence that tainted the investigation. These include…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.1
13 pg
…foregoing
document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing
document is being served to all parties of record via transmission of the Electronic Court Filing
System generated by CM/ECF…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.45
13 pg
…foregoing
document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing
document is being served to all parties of record via transmission of the Electronic Court Filing
System generated by CM/ECF…