…competing proposals for streamlining the unsealing process established by the Order and Protocol for Unsealing Decided Motions. See DE 1224. We write to express our views regarding the parties’ respective submissions, as well as that offered by the Miami Herald…
…Gow, quoted in the Express. 1 Case 1:15-cv-07433-RWS Document 24 Filed 12/17/15 Page 2 of 4 I declare under penalty of perjury that the foregoing is true and correct. /s/ Sigrid S. McCawley…
…press. Defendant repeatedly made that false statement despite the fact that the documents show that Defendant authorized the statement and gave express approval to her press agent to publish the press release – not Barden – with Barden nowhere to be found…
…Maxwell defendants, take no 14 position on our application. Judge Koeltl has expressed a 15 willingness to consider the information that we are seeking by 16 way of this modification. 17 THE COURT: Incidentally, as I understand it, what we…
…Virginia Giuffre in separate pending matters, and shall continue to advance her legitimate legal interests in those matters. As expressly understood by the parties upon the execution of the Confidential Settlement Agreement and Mutual Release, Ms. Giuffre reaffirms her allegations…
…with Virginia Giuffre’s letter in response (Dkt. 1194). While Ms. Maxwell begins her letter by expressing privacy concerns over the soon-to-be- released portion of her transcript, it is clear her real concern, expressed on the second page…
…joint letter. (See dkt. no. 153, Ex. A.) The Court expressed concerns about the parties’ proposal for two reasons. First, the proposed disclosure could “undermine the careful unsealing process agreed to by the parties in Maxwell.” (Dkt. no. 154 at…
…in response to a motion to dismiss. Rule 2(D) of this Court’s Individual Rules of Practice expressly limits memoranda of law in support of and opposition to substantive motions to 25 pages. Because this Opposition actually represents a…
…Order. For example, Doe # 84 is an individual who testified at a deposition, represented by counsel, under the express promise of confidentiality under the Protective Order. This individual accused Mr. Epstein of wrongdoing perpetrated when the individual was minor. During…
…J). Without waiver of the foregoing, Ms. Maxwell responds as follows: Ms. Maxwell retains her First Amendment privilege to express her opinion, to criticize others including Plaintiff, and to comment on matters of public interest, including Plaintiff’s allegations of…
…For example, Doe #84 did not receive notice and it is uncontested that Doe #84 testified only under the express promise of confidentiality. The Second Circuit sua sponte redacted Doe #84’s name from summary judgment pleadings finding that Doe…
…make objections to, and timely seek the Court’s resolution of, confidentiality designations). 2. Language of the Protective Order Courts next look to the express language of the protective order. See In re Ethylene, 255 F.R.D. at 320…
…and] is thus not the considered decision of either this court or the D.C. Circuit.”17 In fact, we have expressly rejected the proposition that “different types of documents might receive different of California, Riverside Cty., 464 U.S…
…inducing parties to provide discovery in a contentious litigation.’” (DE 1113 at 5) Does 1 and 2 wrote this Court and expressed their desire to not have their names released. (DE 1125) Although they did not thereafter submit any objection…
…true.”); Kaminester v. Weintraub, 131 A.D.2d 440, 516 N.Y.S.2d 234 (2d Dep't 1987) (statements accusing plaintiff of personal dishonesty were not constitutionally protected expressions of opinion); Edwards v. Nat’l Audubon Soc., Inc., 556…
…lega l advice' pr ivilege unde r English La w"; "(i]n absence of any express ob ligati on of confidentiality, [Pla intiff] submits that privilege does not attach to communications involving Ross Gow and th e lawyer."; "Und er …
…Maxwell’s arrest, Acting U.S. Attorney Audrey Strauss held a press conference and made numerous comments attacking Ms. Maxwell’s credibility and expressing her opinion of Ms. Maxwell’s guilt, e.g., that she was guilty of “l[ying…
…and] is thus not the considered decision of either this court or the D.C. Circuit.”17 In fact, we have expressly rejected the proposition that “different types of documents might receive different of California, Riverside Cty., 464 U.S…
…and] is thus not the considered decision of either this court or the D.C. Circuit.”17 In fact, we have expressly rejected the proposition that “different types of documents might receive different of California, Riverside Cty., 464 U.S…
…ithout [her] authority or request, " but rather with Maxwell's authority and 57 Case 1:15-cv-07433-RWS Document 872 Filed 04/27/17 Page 58 of 76 by her express request. Gow's testimony establishes Maxwell's…
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