gov.uscourts.nysd.447706.1058.1.pdf PDF
…Preska June 12, 2020 Page 2 of 3 Plaintiff put her reputation (which she contended was destroyed by Ghislaine Maxwell) and her damages at issue in Maxwell. Dershowitz is e…
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gov.uscourts.nysd.447706.1071.0.pdf PDF
…case are not properly in possession of Plaintiff Virginia Giuffre’s (“Ms. Giuffre”) current counsel and thus must be destroyed under the plain terms of the Maxwell protective order. 1. The Maxwell Protective Order At the heart of the dispute…
gov.uscourts.nysd.447706.958.3.pdf PDF
…which have been designated as CONFIDENTIAL shall be returned to the party that designated it CONFIDENTIAL, or the parties may elect to destroy CONFIDENTIAL documents,” whereupon an affidavit confirming destruction must be provided. Since the conclusion of the Giuffre matter…
gov.uscourts.nysd.447706.961.0.pdf PDF
…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…
gov.uscourts.nysd.447706.958.2.pdf PDF
…These two appeals involve some of the confidential documents that you are, apparently, proposing may need to be destroyed now. Until those appeals have been resolved, it would be premature to begin implementing paragraph 12’s provision. We will contact…
gov.uscourts.nysd.447706.1069.0.pdf PDF
…from 20 whom discovery was sought and obtained in the Maxwell matter, 21 didn't rely on the promises made in the protective order that 22 the materials would be destroyed or returned at the conclusion 23 of that case…
gov.uscourts.nysd.447706.1332.17.pdf PDF
…Materials”). The Protective Order prohibits the use of the materials in any other case, and requires the parties to return or destroy the materials at the conclusion of this case. This case concluded in May 2017. Despite our requests, Ms…
gov.uscourts.nysd.447706.1062.0.pdf PDF
…confidential materials will remain so designated through “the conclusion of the case,” at which time they will be returned to the designating party or destroyed. Dershowitz makes the unremarkable observation that the Protective Order contains generic language permitting future modifications…
gov.uscourts.nysd.447706.1219.43.pdf PDF
…She did not. She could have explained that she deleted her account; that her account had been destroyed by the provider; or that she can no longer access her account for various other reasons. She did not say any of…
gov.uscourts.nysd.447706.23.0.pdf PDF
…were published intentionally for the malicious purpose of further damaging a sexual abuse and sexual trafficking victim; to destroy Giuffre’s reputation and credibility” and that Defendant “made her false statements knowing full well that they were completely false. Accordingly…
gov.uscourts.nysd.447706.962.0.pdf PDF
…motions concerns the materials at issue in Ms. Maxwell’s show- cause motion. That motion seeks relief for Ms. Giuffre’s lawyers’ “refus[al] to return or destroy Confidential Materials,” Doc.957, at 1, in their possession, custody and control…
gov.uscourts.nysd.447706.49.0.pdf PDF
…individualized process. And, the “highly confidential” documents are not referenced in paragraph 12. Presumably these types of documents would be destroyed at the conclusion of the case. F. Proposed Paragraph 13 Adds Another Layer of Unnecessary Uncertainty Ms. Maxwell’s…
gov.uscourts.nysd.447706.957.0.pdf PDF
…Materials”). The Protective Order prohibits the use of the materials in any other case, and requires the parties to return or destroy the materials at the conclusion of this case. This case concluded in May 2017. Despite our requests, Ms…
gov.uscourts.nysd.447706.370.0.pdf PDF
… Case 1:15-cv-07433-LAP Document 370 Filed 08/12/16 Page 5 of 17 interests destroyed based on unfounded allegations and a conclusory claim for punitive damages. Unless and until there is a determination of both liability…
gov.uscourts.nysd.447706.1219.19.pdf PDF
… Case 1:15-cv-07433-LAP Document 1219-19 Filed 07/15/21 Page 5 of 17 interests destroyed based on unfounded allegations and a conclusory claim for punitive damages. Unless and until there is a determination of both…
gov.uscourts.nysd.447706.965.0.pdf PDF
…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…
gov.uscourts.nysd.447706.1090.28_4.pdf PDF
…com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved PRIVILEGED GM 001087 CONFIDENTIAL Case 1:15-cv-07433-LAP Doc…
gov.uscourts.nysd.447706.1320.14.pdf PDF
…have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved …
gov.uscourts.nysd.447706.1326.2.pdf PDF
…have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved …
1320-14.pdf PDF
…have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved …
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