giuffre-maxwell
gov.uscourts.nysd.447706.1032.0
1 pg
…Maxwell, No. 15 Civ. 7433 (LAP)
Dear Judge Preska:
Attached please find Ms. Maxwell’s List of Decided Motions, including in the last
column those exhibits and deposition page numbers previously released by the 2nd Circuit.
With this list, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.34.2
3 pg
…London, United Kingdom Public Relations and Communications LinkedIn. Find who you know.
Current ACUITY Reputation First Name Last Name
Education College of Law, Chancery Lane
…
giuffre-maxwell
gov.uscourts.nysd.447706.1047.0
2 pg
…1046 at 1)1, it finds that
proceeding chronologically will minimize disputes during the
motion selection process and will streamline the unsealing
process in the long run. The Court may solicit the parties’
input as to how many motions to…
giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…ever more prominent men. Whenever anyone denies her
allegations, she and her coterie of lawyers threaten to sue or sue for tens of millions of dollars for
“defamation.” Mr. Dershowitz find himself, as Ms. Maxwell did, defending a defamation lawsuit…
giuffre-maxwell
gov.uscourts.nysd.447706.363.6
15 pg
… rather, he is trying to find a way to send this victim of sexual trafficking to
“jail.” “She was hiding in Colorado…but we found her and she will have to be deposed. The end
1
For the limited…
giuffre-maxwell
gov.uscourts.nysd.447706.1196.0
32 pg
…At has become the custom, the Court will announce its
20 general findings relevant to this round of unsealing before
21 marching through its specific findings for each document.
22 As to the Court's general findings, to determine
23…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.36
10 pg
…735, 740-41 (7th Cir. 2008)(finding no abuse of discretion in district court’s
refusal to permit plaintiff to “maximize and dramatize the moment” by calling witness to assert Fifth
Amendment privilege in front of jury); see also Brinks…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.4_1
29 pg
…b. Edwards and Cassell’s Waivers of Attorney-Client and Work Product Privilege in the
Dershowitz Case ............................................................................................................ 15
c. The elements for finding an at issue waiver are satisfied ...........................................…
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
…depending on the
15 time, place and manner of the statement, the Court may find the
16 words to be actionable or not, privileged or not, defamatory in
17 meaning or not.
18 The central problem with this particular complaint…
giuffre-maxwell
gov.uscourts.nysd.447706.164.0
29 pg
…b. Edwards and Cassell’s Waivers of Attorney-Client and Work Product Privilege in the
Dershowitz Case ............................................................................................................ 15
c. The elements for finding an at issue waiver are satisfied ...........................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…own sexual activity” and “her knowledge of the sexual activity
of others.” (DE 316-6 at 10) Judge Sweet overruled Ms. Maxwell’s privacy objections finding
her “privacy concerns are alleviated by the protective order in this case.” Id. Indeed…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.18
23 pg
…depending on the
15 time, place and manner of the statement, the Court may find the
16 words to be actionable or not, privileged or not, defamatory in
17 meaning or not.
18 The central problem with this particular complaint…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.4
35 pg
…for production from Ms. Giuffre's iCloud account.
Attached to this letter, please also find an updated privilege log.
If you have any questions concerning the foregoing, or if there are any issues with the
media, please do not hesitate…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.31
13 pg
…and between (c) defense counsel with joint defense or common interest
privileges concerning obtaining or receiving 'local police[] findings or opinions’ and ‘statements
1
Case 1:15-cv-07433-LAP Document 1328-31 Filed 01/05/24 Page 3…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.39
35 pg
…for production from Ms. Giuffre's iCloud account.
Attached to this letter, please also find an updated privilege log.
If you have any questions concerning the foregoing, or if there are any issues with the
media, please do not hesitate…
giuffre-maxwell
gov.uscourts.nysd.447706.1122.0_2
13 pg
…known or otherwise knowable. In Martindell, the Second Circuit emphasized the federal
government’s substantial investigatory powers as weighing against a finding of compelling need
to modify a protective order. See 594 F.2d at 296. Maxwell and Doe both…
giuffre-maxwell
1320-39
35 pg
…for production from Ms. Giuffre's iCloud account.
Attached to this letter, please also find an updated privilege log.
If you have any questions concerning the foregoing, or if there are any issues with the
media, please do not hesitate…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.11
13 pg
…and between (c) defense counsel with joint defense or common interest
privileges concerning obtaining or receiving 'local police[] findings or opinions’ and ‘statements
1
Case 1:15-cv-07433-LAP Document 1219-11 Filed 07/15/21 Page 3…
giuffre-maxwell
gov.uscourts.nysd.447706.1035.0
2 pg
…aff’d, 814 F.3d 132 (2d Cir. 2016) (disclosing docket
sheets after finding there are no “compelling private interests favoring sealing”). Where a
presumption of the highest weight exists, “[t]he Court is required to order disclosure absent
compelling…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.38
8 pg
…this Court granted Non-Party Boies,
Schiller & Flexner's Emergency Motion to Seal the Affidavit, finding that the discussions were
confidential settlement negotiations.
THE COURT: I agree with you. I think they're confidential settlement discussions.
I'm going to…
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