…Accordingly, Ms. Maxwell requests that the Court exercise its express power under Local Criminal Rule 23.1(h) and enter an Order requiring compliance with that rule to prevent further unwarranted and prejudicial pretrial publicity by the Government, its agents…
…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…
…the Second Circuit, we believe her participation and the participation of other third parties whose privacy interests are implicated are appropriate. Ms. Campbell expressed interest in participating in the post-remand proceedings, and does not oppose adjournment of the conference.
…delete it from your system. Please be advised that the views and opinions expressed in this e-mail may not reflect the views and opinions of Associated Newspapers Limited or any of its subsidiary companies . We make every effort to…
…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…
…Maxwell’s Objections Fail, as the Request Seeks Relevant Discovery Popularly known in mainstream media as the “Lolita Express,”10 Epstein is alleged to have used his private plane to traffic females across state lines for sexual purposes. The flightlogs…
…22. 23. January 3, 2015 Press Statement issued by Ross Gow to Express set forth in “Ghislaine Maxwell: I was not a madam for paedophile,” attached as Exhibit 23. 24. January 4, 2015 Statement by Ghislaine Maxwell to New York…
…claim of privilege under this statute, the information must be imparted to the reporter under a ‘cloak of confidentiality’. There had to be an understanding, express or implied, that the information will not be disclosed” People v. Bova, 118 Misc…
…news/uknews/theroyalfamily/11323872/Prince- h Andrew-denies-having-relations-with-sex-slave-girl.html y 3, 2015 Januar Internet Express http://www.express.co.uk/news/world/550085/Ghislaine-Maxwell-Jeffrey-Epstein- not-madam-paedophile-Florida-court-case-Prince…
…s 'lieutenant', 'flew on the lolita express almost as many times as the disgraced couple' Reports suggest that Ms Maxwell moved 36 times before her arrest last week By Ryan Fahey For Mailonline Published: 20:46 EDT, 11 July 2020…
…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…
…Therefore a finding of liability for [defamation] per se, coupled with an express finding that the [defamation] was intended to injure plaintiff and did in fact cause injury, authorizes the jury to consider and assess punitive damages without any finding…
…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…
…description, Ghislaine Maxwell. 29. All Documents concerning any Communications by You or on Your behalf with any media outlet, including but not limited to the Daily Mail, Daily Express, the Mirror, National Enquirer, New York Daily News, Radar Online, and…
…22. 23. January 3, 2015 Press Statement issued by Ross Gow to Express set forth in "Ghislaine Maxwell: I was not a madam for paedophile," attached as Exhibit 23. 24. January 4, 2015 Statement by Ghislaine Maxwell to New York…
…This would require a marshaling of enormous resources, and under Rule 26(b)(1), there is no need expressed by Defendant to justify this heavy burden. Notably, Defendant has deposed Ms. Giuffre in detail on topics relating to media inquiries…
…Again, the parties and any relevant Does should have the chance to express their views before this Court exercises its discretion. Herald’s Position: The Herald agrees with Plaintiff’s position. 3. Does’ Sealing Motions Plaintiff’s Position: Plaintiff agrees…
…requesting your Stipulation to the adding of Jane Doe #[3] as well. Her true name is [redacted].… As we expressed in our personal meetings a couple years ago, we don’t understand the tactical decision to be adversarial to…
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