…1990s and early 2000s, Plaintiff’s substantial substance abuse, her lack of credibility, her failures of memory and her selective use of law enforcement. Regarding the year 2015, the police reports demonstrate Plaintiff’s tumultuous home life, bearing no relationship…
…1990s and early 2000s, Plaintiff’s substantial substance abuse, her lack of credibility, her failures of memory and her selective use of law enforcement. Regarding the year 2015, the police reports demonstrate Plaintiff’s tumultuous home life, bearing no relationship…
…Y. 2012) (internal citations and quota t ions omitted) (denying motion to lift confidentiality of report of polic in g failures surrounding the murder of a young mother) . "It is presumptively unfair for courts to modify protecti v e orders…
…Entry1 Plaintiff’s Position 231: Defendant’s Motion for Rule 37(b) & (c) for Failure to Unseal and redact only (1) medical information and (2) names and Comply with Court Order identifying information of Non-Parties who have objected to…
…3 Honorable Loretta A. Preska November 18, 2020 Page 2 Whereas Plaintiff suggests that the failure to file an objection results in an automatic unsealing of a Non-Party’s name, the Protocol provides otherwise, requiring the Court to undertake…
…2 Ms. Maxwell notes that Response Brief is filled with irrelevant information and misleading deposition excerpts that are wholly irrelevant to the underlying motion for sanctions for failure to comply with discovery obligations relating to plaintiff’s medical information. These…
…LAP Document 1226 Filed 08/04/21 Page 2 of 4 August 4, 2021 Page 2 of 4 The second issue arises from the parties’ failure to properly make redactions …
…230 Virginia Giuffre filed by Ghislaine Maxwell. Redacted Motion to Compel- Judicial MOTION for Sanctions 37(b) & (c) for Failure to Document 06/20/2016 2…
…meet her burden of overcoming the First Amendment presumption of public access. Maxwell’s failure is especially jarring in light of the public’s interest in this litigation, which involved voluminous documents and testimony about Jeffrey Epstein’s transcontinental sex…
…As to the former, the Protocol explicitly advised Non-Parties that their participation is “optional” and that failure to participate “shall not be deemed consent to the unsealing of any Sealed Materials.” DE 1108 at 3(f). The Court also…
…Maxwell’s attempt to justify complete closure based on a Non-Party’s failure to object—regardless of the substance of the document that mentions the Non-Party— therefore flies in the face of the presumption of public access. 4…
…admission or statement given by the accused, or the refusal or failure of the accused to make any statement,” “the identity, testimony or credibility of prospective witnesses,” “the possibility of a plea of guilty to the offense charged or a…
…LAP Document 991-1 Filed 09/25/19 Page 7 of 48 MOTION for Sanctions 37(b) & (c) for Failure to Comply 06/20/2016 231 Motion to Compel with Court Order and Failure to Comply with Rule 26(a) …
…2 Ms. Maxwell notes that Response Brief is filled with irrelevant information and misleading deposition excerpts that are wholly irrelevant to the underlying motion for sanctions for failure to comply with discovery obligations relating to plaintiff’s medical information. These…
…RELIEF For the foregoing reasons, Ms. Giuffre respectfully asks this Court to give the jury an adverse inference instruction for failure to produce electronically stored information, exclude Barden from testifying at trial, forbid any use of the Barden documents at…
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