giuffre-maxwell
gov.uscourts.nysd.447706.1331.29
4 pg
…P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following
disclosures:
I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE
INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH
PARTICULARITY IN THE PLEADINGS
1. Ghislaine Maxwell
c/o Laura A. Menninger, Esq…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.4
4 pg
…P. 26(a)(l)(A), Defendant Ghislaine Maxwell makes the following
disclosures:
I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE
INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH
PARTICULARITY IN THE PLEADINGS
1. Ghislaine Maxwell
c/o Laura A. Menninger, Esq…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…the Court ordered that prior to motions practice, the
parties were to set an agenda on the disputed issue in writing and have a meeting of substance
prior to filing a motion. “So I would say exchange writing as to…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.43
4 pg
…ABC
January 6, 2015 Tuesday
LENGTH: 942 words
HEADLINE: Prince Andrew under pressure as Palace disputes teen sex scandal
claims
REPORTERS: Philip Williams
BODY:
LEIGH SALES, PRESENTER: It's been a few years since Britain's Royal Family has
been…
giuffre-maxwell
gov.uscourts.nysd.447706.590.1
4 pg
…ABC
January 6, 2015 Tuesday
LENGTH: 942 words
HEADLINE: Prince Andrew under pressure as Palace disputes teen sex scandal
claims
REPORTERS: Philip Williams
BODY:
LEIGH SALES, PRESENTER: It's been a few years since Britain's Royal Family has
been…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.17
12 pg
…
A. I have legal advice that I took.
Q. But you knew in early January by making a statement calling Virginia a liar
that you were subjecting yourself to a legal dispute with her?
Q. I took legal advice as…
giuffre-maxwell
gov.uscourts.nysd.447706.1254.0
18 pg
…4 not remember a man with his name. Thus, he has no relevance to
5 the issues in dispute in this matter. Given the sensitive and
6 potentially salacious issues in this lawsuit, there is no
7 public value in…
giuffre-maxwell
gov.uscourts.nysd.447706.1312.0
9 pg
…1050 (2d Cir. 1995)). Here, the materials at issue were filed on the docket
in connection with discovery disputes, are judicial documents, and are afforded a presumption of
public access that, although somewhat lesser than that afforded to dispositive motions…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.19
15 pg
…A. I have legal advice that I took.
6 Q. But you knew in early January by
7 making a statement calling Virginia a liar
8 that you were subjecting yourself to a legal
9 dispute with her?
10 MR…
giuffre-maxwell
gov.uscourts.nysd.447706.49.0
12 pg
…U.S. 20, 35 (1984).
Confidentiality orders are intended “to ‘secure the just, speedy, and inexpensive
determination’ of civil disputes by encouraging full disclosure of all evidence that might
conceivably be relevant.” Martindell v. Int’l Tel. & Tel. Corp., 594…
giuffre-maxwell
gov.uscourts.nysd.447706.551.0
17 pg
…citizens in the discussion of these problems. Cernovich Media cannot conduct
its Forth Estate function if this Court allows the Parties to conduct their dispute outside of the
normal sunlight of transparency and accessibility. The public has a right to…
giuffre-maxwell
gov.uscourts.nysd.447706.436.0
15 pg
…Ms. Giuffre
attempts no rejoinder to the reasoning of Mokhiber and its progeny: that modern discovery
motions are core judicial processes that “may prove decisive to the outcome of particular
disputes” and therefore must be open to public monitoring. Mokhiber…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…in the Subpoena, which, on its face,
is, at best, tangentially related to the dispute in this case. And there are ample alternative sources
for the information. (As a starting point, in order to obtain information about payments to, or
…
giuffre-maxwell
gov.uscourts.nysd.447706.15.0
29 pg
…Colo. 1979) (recognizing qualified privilege defense
for protecting one’s interest).
9
are pertinent. The plaintiff selected the forum for the dispute, and
in that forum it would certainly tend to repel, or minimize the
harmful tendency of the…