…District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S MOTION TO MAINTAIN CONFIDENTIALITY DESIGNATION Plaintiff Virginia Giuffre, by and through her undersigned couns…
…L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ____________________________/ DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF PLAINTIFF’S MOTION TO EXCLUDE DEFENDANT’S DESIGNATION OF DEPOSITION EXCERPTS OF ALAN DERSHOWITZ IN A…
…Re: Giuffre v. Maxwell Dear Ms. Schultz: Pursuant to paragraph 11 of the Protective Order in this case Ms. Maxwell disputes the confidential designation of documents produced by Ms. Maxwell to the Plaintiff, GM 748-849. Your email does not…
…a mechanism by which the parties may designate as “confidential” documents that would warrant protection under Federal Rule of Civil Procedure 26(c). The designation is important, since it confers upon the document the Court’s imprimatur that, in fact…
…seek to overturn the protective order as follows: “The Protective Order states that parties can object to the confidentiality designations: “A party may object to the designation of particular CONFIDENTIAL INFORMATION by giving written notice to the party designating the…
…Intervenor’s June 21, 2017 letter and its attachments, and remove the confidentiality designation from several related emails and attachments that the parties previously designated confidential (RANSOME_000273-557) (“the Emails”). The Emails will demonstrate that Ms. Ransome’s inflammatory…
…that this is fishing with a drift net. We decline your request to engage in this exercise. Regarding redacted police reports that plaintiff designated “confidential”: We objected to plaintiff’s confidentiality designation, and plaintiff failed to file a motion in…
…all Formatted: Font: 12 pt, Font color: Black Formatted: Indent: First line: 0.5", Space disclosures during discovery. Designations under this Order shall be made sparingly, with care, Before: 0 pt, Line spac…
…be placed near the Bates number. 8. Designation of a document as CONFIDENTIAL INFORMATION shall constitute a representation that such document has been reviewed by an attorney for the designating party, that there is a valid and good faith basis…
…fairly obvious that this is fishing with a drift net. We decline your request to engage in this exercise. Regarding redacted police reports that plaintiff designated “confidential”: We objected to plaintiff’s confidentiality designation, and plaintiff failed to file a …
…the parties unrestricted authority to disclose publicly the confidential materials from Maxwell--not least of all because the parties only may agree to downgrade confidentiality designations for materials that the “designating party has subsequently produced in this action,” i.e.…
… 2. It defines Confidential Information to include, inter alia, “information filed under seal or designated as ‘Confidential’ in another action for which the confidentiality designation or seal has not been lifted.” Id. Thus, “Confidential Information” encompasses sealed information from Maxwell…
…2016. It states: “Designation of a document as CONFIDENTIAL INFORMATION shall constitute a representation that such document has been reviewed by an attorney for the designating party, that there is a valid and good 4 Case 1:15-cv…
…from , designated as Confidential by Plaintiff in this case. Such Confidential designation has been challenged by the defense. 3. Attached as Exhibit B is a true and correct copy of records from …
… Yes. 23 MR. MILLER: -- withdrew their objection to the 24 confidential designation. 25 THE COURT: Yes. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 Case 1:15-cv-07433-LAP Document 931 Filed 11/21/17 Page 4 of…
…just such a reservoir for her profit motives. IV. Category 4: Trial deposition designations and counter-designations. The parties designated and counter-designated many hundreds of pages from deposition transcripts. Such designations are made routinely under Rule 32(a)(6…
…30, 2018) (“[A] ‘Confidential’ designation made pursuant to a protective order does not by itself overcome the presumption of public access once the document containing the designation becomes a judicial document.”). Finally, whether the document in question is already public…
…document title, are deemed “Confidential Information.” The Government shall clearly mark all pages or electronic materials containing Confidential Information, or folder or document titles as necessary, with “confidential” designations. 8. Confidential Information may contain personal identification informat…
…and deponents reasonably relied on protective order); DE 1062 at 3-6 (protective order tracks permissible scope under Rule 26(c)(1), includes provisions to challenge improper designation of confidentiality, contained no temporal limit, and appropriately limited use of confidential…
…Rotger, 2018 WL 11214575, at *1 (“[A] ‘Confidential’ designation made pursuant to a protective order does not by itself overcome the presumption of public access once the document containing the designation becomes a judicial document.”). Doe 151’s belief in…
Comments