giuffre-maxwell
gov.uscourts.nysd.447706.308.0
7 pg
…York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF VIRGINIA GIUFFRE’S MOTION FOR FINDING
OF CIVIL CONTEMPT AGAINST SARAH KELLEN
FOR IGNORING SUBPOEN…
giuffre-maxwell
gov.uscourts.nysd.447706.1315.0
51 pg
… The following are the Court’s findings as to the Does
designated following its particularized review of the documents noted:
Case 1:15-cv-07433-LAP Document 1315 Filed 12/18/23 Page 2 of 51
Case 1:15-cv…
giuffre-maxwell
gov.uscourts.nysd.447706.1346.0
3 pg
…no. 1315] summarizing its
findings following a particularized review of the documents noted therein and immediately
staying its order for fourteen days to allow any impacted Does an opportunity to appeal.
Prior to expiration of the fourteen-day stay, Does…
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.447706.1319.0
2 pg
…1315) summarizing its findings following a particularized
review of the documents noted therein and immediately staying its
order for fourteen days to allow any impacted Doe an opportunity
to appeal.
The Court received inquiries from two Does seeking to remain…
giuffre-maxwell
gov.uscourts.nysd.447706.441.0
18 pg
…C ou rt’s A pril21,2016,ru lingM s.Giu ffre has mad e significantefforts to try to
trackd own and collectany med icalrecord she can find from 1999 to the present,inclu d ingpayingall
fees associated withthatcollection process…
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.447706.1125.0_2
5 pg
… and relatedly, that Does 1 and 2 are (for now)
proceeding pro se further counsels in favor of a finding that the
September 25 Email is not a formal objection for purposes of
Paragraph 2(d) of the Protocol. Here…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…September
2001. Additionally, the Pew Research Center published findings that certain demographics have
higher internet usage, including many demographics to which Defendant belongs. For example,
higher rates of internet usage are found among younger adults (Defendant was 38 in 1999…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.30
40 pg
…11 together. Like I said, that they would all go out
12 to clubs to pick up girls and try and find them to
13 bring back for Jeffrey. And then she told me about
14 how, like I said…
giuffre-maxwell
gov.uscourts.nysd.447706.1305.0
4 pg
…procedural history of the case, and the issues on appeal.
“In reviewing a district court’s order to seal or unseal, we examine the court’s factual
findings for clear error, its legal determinations de novo, and its ultimate decision…
giuffre-maxwell
gov.uscourts.nysd.447706.1126.0
3 pg
…the issues on
appeal. 1
When reviewing a district court’s decision to seal a filing or maintain such a seal, “we
examine the court’s factual findings for clear error, its legal determinations de novo, and its ultimate
decision…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.33
12 pg
…September
2001. Additionally, the Pew Research Center published findings that certain demographics have
higher internet usage, including many demographics to which Defendant belongs. For example,
higher rates of internet usage are found among younger adults (Defendant was 38 in 1999…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.1
8 pg
…Palm Beach County State Attorney’s Office, Public Records Request
No.: 16-268, Disc 7 (GIUFFRE007590) at Page 2305. Upon finding this undisclosed email
accounts, the undersigned sent a follow-up letter to Ms. Menninger, stating: “please include a
search…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.22
40 pg
…11 together. Like I said, that they would all go out
12 to clubs to pick up girls and try and find them to
13 bring back for Jeffrey. And then she told me about
14 how, like I said…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.37
11 pg
…happened when she approached you?
12 A. She asked me if I could tell her how to
13 find someone that would come and work at her house.
14 She wanted to know if there was, like, a bulletin
15 …
giuffre-maxwell
gov.uscourts.nysd.447706.1220.0
17 pg
…well
8 as the documents relevant to those motions.
9 As before, the Court will announce its general
10 findings relevant to this round of unsealing, marching through
11 each specific findings on each document.
12 In arriving at these…
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.447706.1330.11
12 pg
…September
2001. Additionally, the Pew Research Center published findings that certain demographics have
higher internet usage, including many demographics to which Defendant belongs. For example,
higher rates of internet usage are found among younger adults (Defendant was 38 in 1999…
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 ...........................................…
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