gov.uscourts.nysd.447706.1328.44.pdf PDF
…11lacc for the purpose of 8 Q Isn't take true you have IJeen on Jeffrey 8 engaging i11 sexual activity with minors at his 9 Epstein's airplane with Dong Band, nm Clinton's 9 destination? 10 righthnnd man'…
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gov.uscourts.nysd.447706.1201.26.pdf PDF
…new photography exhibition +16 Iconic British model Lolita express: Epstein's Boeing 727 on the grou…
gov.uscourts.nysd.447706.563.0.pdf PDF
…L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S MOTION TO EXCLUDE DEFENDANT’S DESIGNATION OF DEPOSITION EXCERPTS OF VIRIGINA GIUFFRE IN AN UNRELATED CASE …
gov.uscourts.nysd.447706.201.0.pdf PDF
…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…
gov.uscourts.nysd.447706.564.0.pdf PDF
…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 VIRIGINA GIUFFRE I…
gov.uscourts.nysd.447706.561.0.pdf PDF
…L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S MOTION TO EXCLUDE DEFENDANT’S DESIGNATION OF DEPOSITION EXCERPTS OF ALAN DERSHOWITZ IN AN UNRELATED CASE …
gov.uscourts.nysd.447706.562.0.pdf PDF
…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…
gov.uscourts.nysd.447706.1199.1_1.pdf PDF
…be maintained as confidential. Pursuant to the Court’s Protective Order, Ms. Giuffre marked as confidential highly sensitive documents and Defendant is now challenging that designation. Defendant objects to maintaining as confidential police reports involving Ms. Giuffre, including two police…
gov.uscourts.nysd.447706.1199.3_1.pdf PDF
…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…
gov.uscourts.nysd.447706.624.0.pdf PDF
…extension of time to respond to "Plaintiffs Motion to Exclude Designation of Deposition Excerpts of Alan Dershowitz in an Unrelated Case" (ECF 561) and "Plaintiffs Motion to Exclude Defendant's Designation of Deposition Excerpts of Virginia Giuffre in an Unrelated…
gov.uscourts.nysd.447706.829.0.pdf PDF
…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…
gov.uscourts.nysd.447706.40.0.pdf PDF
…of a Protective Order in this case, but does oppose a Protective Order in the form proposed by Defendant because it is overly broad and can lead to abuse and over designation of material as “confidential.” Ms. Giuffre’s proposal1…
gov.uscourts.nysd.447706.1328.20.pdf PDF
…HAS WAIVED ANY ARGUMENT AS TO CONFIDENTIALITY ................ 9 A. Plaintiff Failed to Timely Move this Court to Uphold Her Designation of the Documents as Confidential ................................................................................................................. 9 B. Plaintiff’s Counsel Has …
gov.uscourts.nysd.447706.1199.16_1.pdf PDF
…from when she was a child, some of them concerning her being raped when only 14 years. Defendant’s challenge to Ms. Giuffre’s confidentiality designation is without merit, and it is for improper purposes. Therefore, it should be denied…
gov.uscourts.nysd.447706.1332.15.pdf PDF
…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…
gov.uscourts.nysd.447706.1296.16.pdf PDF
…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…
gov.uscourts.nysd.447706.1200.13_1.pdf PDF
…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…
gov.uscourts.nysd.447706.1335.5.pdf PDF
…them from when she was a child, some of them concerning her being raped when only 14 years. Defendant’s challenge to Ms. Giuffre’s confidentiality designation is without merit, and it is for improper purposes. Therefore, it should - be…
gov.uscourts.nysd.447706.41.5.pdf PDF
…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…
gov.uscourts.nysd.447706.1296.17.pdf PDF
…if the Court allows Plaintiff Virginia Giuffre to remove the confidentiality designation concerning the Ransome deposition—an action that would require modification of the Protective Order in this case —it also simultaneously remove the confidentiality designation from several related emails…
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