gov.uscourts.nysd.447706.666.0.pdf PDF
…OF NEW YORK --------------------------------------------------X .. ............................................. VIRGINIA L. GIUFFRE, Plaintiff, v. …
…OF NEW YORK --------------------------------------------------X .. ............................................. VIRGINIA L. GIUFFRE, Plaintiff, v. …
…x MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION UNDER THE FOURTH AMENDMENT, MARTINDELL, AND THE FIFTH AMENDMENT TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT’S SUBPOENA TO AND TO DISMISS COUNTS FIVE AND SIX …
…A. Requests For Production Specifically State They Relate Only to Punitive Damages, Acknowledging the Information is Otherwise Irrelevant .................................................... 1 B. Sale of Townhome is Irrelevant and Not Calculated to Lead to the Discovery of Admissible Evidence ....................…
…ECF No. 1059. Maxwell’s position is the height of impracticality. The evidence Professor Dershowitz seeks from Giuffre v. Maxwell is clearly discoverable given the overlapping allegations in the cases at issue, and she does not and cannot argue otherwise…
…Argument About Her Right to a Fair Criminal Trial Was Raised and Rejected on Appeal. ...............................................................................................8 IV. Maxwell’s Argument Concerning Potential Evidence at Her Criminal Trial Was Raised on Appeal and is Irrelevant to t…
…Jane Doe 1 and Jane Doe 2’s Protective Motion Pursuant to Rule 15 to Amend Their Pleadings to Conform to Existing Evidence and to Add Jane Doe 3 and Jane Doe 4 as Petitioners (“Rule 15 Motion”) (DE 311)…
…Protective Orders and Court Orders (“Motion to Compel”) 2. Motions in Limine re. Admissibility of Evidence and Related Orders (“Motion in Limine re. Admissibility of Evidence”) 3. Motions in Limine re. Expert Testimony and Related Orders (“Motion in Limine re…
…Jane Doe 1 and Jane Doe 2' s Protective Motion Pursuant to Rule 15 to Amend Their Pleadings to Conform to Existing Evidence and to Add Jane Doe 3 and Jane Doe 4 as Petitioners (" Rule 15 Motion") ( DE 311)…
…TO COMPEL AND RELATED MOTIONS FOR PROTECTIVE ORDERS AND COURT ORDERS ...................................................... 3 II. CATEGORY 2: MOTIONS IN LIMINE RE ADMISSIBILITY OF EVIDENCE AND RELATED ORDERS .........................................................................................…
…Jane Doe 1 and Jane Doe 2’s Protective Motion Pursuant to Rule 15 to Amend Their Pleadings to Conform to Existing Evidence and to Add Jane Doe 3 and Jane Doe 4 as Petitioners (“Rule 15 Motion”) (DE 311)…
…Jane Doe 1 and Jane Doe 2’s Protective Motion Pursuant to Rule 15 to Amend Their Pleadings to Conform to Existing Evidence and to Add Jane Doe 3 and Jane Doe 4 as Petitioners (“Rule 15 Motion”) (DE 311)…
…the January 2015 statement would violate the First Amendment. ............................................................................................................ 16 C. Plaintiff should be barred from introducing into evidence any republication of an excerpt from the Ja…
…Preska September 18, 2019 Page |2 2. Motions in Limine re. Admissibility of Evidence and Related Orders (“Motion in Limine re. Admissibility of Evidence”) 3. Motions in Limine re. Expert Testimony and Related Orders (“Motion in Limine re. Expert”) 4…
…Ghislaine Maxwell) and her damages at issue in Maxwell. Dershowitz is entitled to discover and use that evidence here. Dershowitz can easily surpass the standard required to access materials under the Protective Order. When there has been “reasonable reliance” on…
…materials “are judicial documents” and that no countervailing interests justify continued sealing, see id. at 10-11 – without proffering any specific argument or supporting evidence. As such, the USVI has failed to provide any basis for summarily circumventing the individualized…
…trial. Ms. Maxwell’s responses to Plaintiff’s Interrogatories are based on information currently known to her and are given without waiving Ms. Maxwell’s right to use evidence of any subsequently discovered or identified facts, documents or communications. Ms…
…brought on plowed ground. In October 2017 third parties sued by an alleged Epstein victim moved to modify the Protective Order to permit them to “use all evidence” produced by a non-party witness in this case. Doc.924 (filed…
…burden (“Privacy Interests”). CI-4 - Preserving the fundamental rights of suspects or others under criminal investigation – including due process right to a fair trial and impartial jury unimpaired by excessive publicity, release of potentially inadmissible evidence for the Criminal Action…
… CI-6; Doe to and deposition testimony potential CI-7 remain evidence. sealed (#338- 9) …
…2. Judge Sweet carefully considered the parties’ arguments and the evidence at issue before deciding whether to exclude the evidence at issue prior to trial—he did not simply categorically deny all motions in limine to be raised at trial…
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