gov.uscourts.nysd.447706.24.3.pdf PDF
Case 1:15-cv-07433-RWS Document 24-3 Filed 12/17/15 Page 1 of 3 EXHIBIT 3 Case 1:15-cv-07433-RWS Document 24-3 Filed 12/17/15 Page 2 of 3 Express. Home of…
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gov.uscourts.nysd.447706.1226.0.pdf PDF
…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…
gov.uscourts.nysd.447706.1337.0.pdf PDF
… (Dkt. no. 1254.) This Court expressly ordered that lines 217:17-19 of the deposition transcript should remain under seal because they contained a mistaken transcription, and the answer transcribed was not the answer actually given. Counsel shall re-file…
gov.uscourts.nysd.447706.223.6.pdf PDF
…proceed with a VI deposition and to accept service for that deposition. I understand the issue expressed below and will prgmptly communicate with Ms Maxwell's counsel in order to determine her position. Thanks, Marty From: Sigrid McCawley Sent: Thursday…
gov.uscourts.nysd.447706.24.0.pdf PDF
…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…
gov.uscourts.nysd.447706.1078.1.pdf PDF
…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…
gov.uscourts.nysd.447706.1250.0.pdf PDF
…privacy merely because they have played a role in a civil or criminal case against perpetrators. As an initial matter, Intervenors seek to unseal documents concerning the alleged sexual abuse of minors over the express wishes of those victims. Yet…
gov.uscourts.nysd.447706.1224.0.pdf PDF
…process. At the July 26 meet and confer, Maxwell’s counsel expressed that they would be unable to carry out the Court’s suggestion due to scheduling conflicts until January of next year, and asserted 1 The Non-Party Objectors…
gov.uscourts.nysd.447706.1328.8.pdf PDF
…1. 12. Attached hereto as Sealed Exhibit 10 is a true and correct copy of January 22, 2015 Dailymail.co article “All aboard The Lolita Express’: Flight Logs. 13. Attached hereto as Sealed Exhibit 11 is a true and correct…
gov.uscourts.nysd.447706.1201.18.pdf PDF
…1. 12. Attached hereto as Sealed Exhibit 10 is a true and correct copy of January 22, 2015 Dailymail.co article “All aboard The Lolita Express’: Flight Logs. 13. Attached hereto as Sealed Exhibit 11 is a true and correct…
gov.uscourts.nysd.447706.515.0.pdf PDF
…ATTACHED IN 2011 WHEN SHE FORMED AN INTENT TO JOIN THE CVRA LITIGATION Plaintiff concedes she willfully and deliberately destroyed while she prepared to join the CVRA litigation and while she was represented by current counsel for that express purpose…
gov.uscourts.nysd.447706.997.0.pdf PDF
…50). But we agree. It would be legal error for a court to conclude that a given filing is non-judicial merely because the court did not expressly rely on that filing “in adjudicating a motion.” But, of course, that…
gov.uscourts.nysd.447706.1295.5.pdf PDF
…SHE FORMED AN INTENT TO JOIN THE CVRA LITIGATION Plaintiff concedes she willfully and deliberately destroyed her journal in 2013 while she prepared to join the CVRA litigation and while she was represented by current counsel for that express purpose…
gov.uscourts.nysd.447706.1331.19.pdf PDF
…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…
gov.uscourts.nysd.447706.931.0.pdf PDF
…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…
gov.uscourts.nysd.447706.1295.10.pdf PDF
… It's -- you're 11 seeking information to be able 12 to -- the witness has already 13 expressed fear about her -- 14 people currently going after her. 15 So we would object to that 16 intimidation of a nonparty 17…
gov.uscourts.nysd.447706.1201.22_1.pdf PDF
…down and sat in the stool 10 exactly the way the girls that I mentioned to 11 you sat at Jeffrey's house, with no 12 expression and with their head down. But we 13 could tell that she was…
gov.uscourts.nysd.447706.1200.16_1.pdf PDF
…in the stool 10 exactly the way the girls that I mentioned to 11 you sat at Jeffrey's house, with no 12 expression and with their head down. But we 13 could tell that she was very nervous. 14 …
gov.uscourts.nysd.447706.1195.0_2.pdf PDF
…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…
gov.uscourts.nysd.447706.303.0.pdf PDF
…than an answer to an interrogatory. See Fed.R.Civ.P. 33(c) (expressly authorizing the use of interrogatories at trial to extent permitted by the law of evidence). A response which is nothing more than a cross-reference by…
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