gov.uscourts.nysd.447706.1328.44.pdf PDF
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…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. ________________________________/ PLAINTIFF’S MOTION TO EXCLUDE DEFENDANT’S DESIGNATION OF DEPOSITION EXCERPTS OF ALAN DERSHOWITZ IN AN UNRELATED CASE …
…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…
…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…
…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…
…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…
…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…
…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 …
…Mar. 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…
…A. The Protective Order included a mechanism for one party to challenge another party’s confidentiality designation (such a challenge never occurred) and provided that it did not apply to any information or material disclosed at trial. (Because the case…
…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…
…Supp. 2d 318, 341 (S.D.N.Y. 2003) (granting modification of protective order where stipulated order “allowed for unilateral designation of an exhibit as protected material, and it did not list specific documents, or delineate the kinds of documents…
…Southern District of Florida, 08-cv-80736-KAM pleadings to include: a. Motion for Limited Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic Filing (July 28, 2008) (Doc. # 16) b. Notice of Change of Address and…
…and Ms. Giuffre needs that testimony to prove her defaination claim against Defendant. 2 Ms. Giuffre is no Ion er seeking the deposition testimony o 2 Case 1:15-cv-07433-LAP Document 1137-16 Filed 10/22/20…
…the designations in correspondence have been modified here – as indicated by brackets – to track the current designation in the pleadings. 4 Case 1:15-cv-07433-LAP Case 9:08-cv-80736-KAM Document Document 1137-15 …
…by contrast, the USVI does not know who has testified in depositions that are sealed or otherwise shrouded by confidentiality designations. This is why the highlighted 5 Case 1:15-cv-07433-LAP Document 1122 Filed 09/24/20…
…Southern District of Florida, 08-cv-80736-KAM pleadings to include: a. Motion for Limited Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic Filing (July 28, 2008) (Doc. # 16) b. Notice of Change of Address and…
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