…Plaintiff, v. 15-cv-07433-RWS Ghislaine Maxwell, Defendant. [PROPOSED] PROTECTIVE ORDER Upon a showing of good cause in support of the entry of a protective order to protect the discovery and dissemination of conf…
…DERSHOWITZ, Defendant. VIRGINIA L. GIUFFRE, Plaintiff, No. 15 Civ. 7433 (LAP) -against- ORDER GHISLAINE MAXWELL, Defendant. LORETTA A. PRESKA, Senior United States District Judge: The Co…
…2 of 35 2 G3hdgium 1 THE COURT: Thank you all very much. I'm sorry for 2 the inconvenience that I have imposed upon you. I'm sorry 3 about the inconvenience that you have imposed upon me. 4 …
…2) the need of the party for the documents, 3) the breadth of the document request, 4) the time period covered by it, 5) the particularity with which the documents are described, and 6) the burden imposed. Id. 1 …
…2) the need of the party for the documents, 3) the breadth of the document request, 4) the time period covered by it, 5) the particularity with which the documents are described, and 6) the burden imposed. Id. 1 …
…08/31/20 Page 2 of 3 of any comments received.” (Id. at 2.)1 The Court writes to provide that update. Nonparties were permitted to submit comments on the proposed disclosure to Mr. Dershowitz no later than August 25…
…957), and states as follows. INTRODUCTION1 Ms. Maxwell has argued that counsel for Ms. Giuffre have been ordered by this Court to immediately destroy certain materials covered by the protective order in this matter. Counsel for Mr. Giuffre stand ready…
…all refer to it? 20 MR. MILLER: We refer to it as Jane Doe. 21 THE COURT: Okay. 22 MR. MILLER: Let me back up and give you background. 23 THE COURT: No, no. Thanks very much. 24 MR. MILLER: …
…Virginia Giuffre in separate pending matters, and shall continue to advance her legitimate legal interests in those matters. As expressly understood by the parties upon the execution of the Confidential Settlement Agreement and Mutual Release, Ms. Giuffre reaffirms her allegations…
…Scarola, at which 22 time I will give opportunity for re-direct based 23 upon the topics that you've raised. 24 MR. SCAROLA: With the understanding that 25 re-direct is going to be limited to the area of…
…36 2 G3hdgium 1 THE COURT: Thank you all very much. I'm sorry for 2 the inconvenience that I have imposed upon you. I'm sorry 3 about the inconvenience that you have imposed upon me. 4 But having…
…s, 14 and was dismissed shortly thereafter. Two times since May we 15 have asked for agreed upon protocol with the plaintiff's 16 counsel to finish up destroying or exchanging-back confidential 17 documents. The first request was shortly…
…2) the need of the party for the documents, 3) the breadth of the document request, 4) the time period covered by it, 5) the particularity with which the documents are described, and 6) the burden imposed. Id. 1 …
…Plaintiff, v. 15-cv-07433-RWS Ghislaine Maxwell, Defendant. [PROPOSED] PROTECTIVE ORDER Upon a showing of good cause in support of the entry of a protective order to protect the discovery and dissemination of conf…
…Objection by arguing for un-sealing. Any argument by an Original Party for sealing would be covered by 2(f) and not in opposition to the Non-Party. 2(f): The Court in its Order at ¶ 5 recognized the right…
…be heard is both Constitutionally required and appropriate under the circumstances. This case is of obvious, significant public interest, and the events underlying the lawsuit have been covered extensively in the press, including in the Post and Daily News. However…
…Maxwell’s Brief). This argument shows Mr. Dershowitz is not above mischaracterizing his opponent’s position to set up a straw man argument for himself. We said, “Materials submitted to the court solely so that the court may decide whether…
…to that, your Honor, I'm really 17 commenting on the issue of what someone could reasonably have 18 relied upon, and the issue that someone would have thought of 19 at that point in time was public disclosure, and…
…allegations nor upon the exercise of a reasonable inquiry has she located any actions that she took in that regard. 3. Name every blog, television station, newspaper, or other media or public outlet that you are aware covered the January…
…594 F.2d 291 (2d Cir. 1979). She claims it is irrelevant because it concerned the government’s – rather than the public’s – right to access documents covered by a protective order. In fact, this unsealing came about after a…
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