… Salas by Salas v. Wang, 846 F.2d 897 (3d Cir. 1988)...................................................................................................... 11 U.S. Underwriters Ins. Co. v. LCRF Enterprises, LLC, No. 10-CV-3418 GBD, 2012 WL 993502 (S.D.N.Y. Mar. 26, 2012)...................................... 11 Fifth Amendment…
…3 unsealing or whose time to object argument of counsel violative of C1-4 to unsealing has not yet expired. Local Criminal Rule 23.1.…
…the Court’s Order [DE 134] dated May 2, 2016.1 ARGUMENT Statements made by witnesses to law enforcement are protected by the public interest privilege, which “exists to encourage witnesses to come forward and provide information in criminal investigations . . …
…2 231 6.20.16 information, and argument of C1-3 counsel violative of Local C1-4 Criminal Rule 23.1. C1-1 …
…to promote her sham non-profit, Victims Refuse Silence, Inc. 2. No law enforcement agency pursued any criminal charges against Ms. Maxwell, even after both federal and state investigators fully scrutinized Ms. Maxwell’s one-time 1 emp…
…seal records concerning underage victims – well beyond replacing their names with initials – and victims do not forego their rights to privacy merely because they have played a role in a civil or criminal case against perpetrators. As an initial matter…
…cs Codo, Sections 1591(aX1) and 2; and IT APPEARING that Epstein seeks to resolve globally his state and federal criminal liability and Epstein undentands and acknowledges that, in exchan&e for the benefits provided by this agreement, he agrees…
…FILED Court Keep sealed – Non-Party reliance on ordered other Protective Order & Release of inadmissible CI-1; CI-2; excerpts information in violat…
…round one of unsealing) on this Court’s analysis in this round two, and the impact of any unsealing on Ms. Maxwell’s pending criminal trial. Ms. Maxwell also needed to address plaintiff’s request to keep certain items under…
…Main Street Armonk, NY 10504 Paul G. Cassell (Pro Hac Vice) Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the …
…and meaningful access to these records. Ms. Maxwell's submission argues that this proposed process is too onerous while her counsel prepare for her criminal trial, but her proposal (and the status quo) require far more duplication and therefore more…
…Main Street Armonk, NY 10504 Paul G. Cassell (Pro Hac Vice) Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the …
…Indeed, in her original objection to unsealing, Ms. Maxwell argued that the specter of ongoing criminal investigations into unknown individuals associated with Jeffrey Epstein--a group that, of course, includes Ms. Maxwell--loomed large over the Court-ordered unsealing 1…
…Florida. 12. In the NPA, the United States additionally agreed that it would not institute any federal criminal charges against any potential co-conspirators of Epstein. 13. As a co-conspirator of Epstein, Maxwell was consequently granted immunity in the…
…the United States District Courts; b. The Federal Rules of Civil Procedure; c. The Federal Rules of Criminal Procedure; d. The Federal Rules of Evidence; e. The…
…promote her fantastical story to the media; second, her tactical plan to bully potential witnesses into silence by inappropriate threat of criminal prosecution. The Court should reject the “non-protective” order proposed by Plaintiff and enter the reasonable, and enforceable…
…Florida. 12. In the NPA, the United States additionally agreed that it would not institute any federal criminal charges against any potential co-conspirators of Epstein. 13. As a co-conspirator of Epstein, Maxwell was consequently granted immunity in the…
…Florida. 12. In the NPA, the United States additionally agreed that it would not institute any federal criminal charges against any potential co-conspirators of Epstein. 13. As a co-conspirator of Epstein, Maxwell was consequently granted immunity in the…
…or in the Alternative Modification of the Protective Order. 3. I am the Ronald N. Boyce Presidential Professor of Criminal Law and University Distinguished Professor of Law at the S.J. Quinney College of Law, where I teach criminal procedure…
…2016 Order) at 18-21. Now that it is Ms. Maxwell’s right to due process in a criminal trial, plaintiff completely reverses course and contends that “Maxwell’s criticisms are misguided because they are based on the proposition that…