giuffre-maxwell
gov.uscourts.nysd.447706.986.0
60 pg
…Court
500 Pearl Street
New York, NY 10007
Re: Giuffre v. Maxwell,
Case No. 15-cv-07433-LAP
Dear Judge Preska:
Plaintiff submits the following categories of documents pursuant to the Court’s Order of
September 5, 2019. Dkt. 982…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.35
7 pg
…when and where the following proceedings were
reported by:
Michele Cameron
Magna Legal Services
866-624-6221
Case 1:15-cv-07433-LAP Document 1218-35 Filed 07/15/21 Page 3 of 7
…
giuffre-maxwell
gov.uscourts.nysd.447706.185.4
10 pg
…3 and Jane Doe 4 as Petitioners (“Rule 15 Motion”) (DE
311). Both motions are ripe for review. For the following reasons, the Court concludes that they
should be denied.
I. Background
This is an action by two unnamed petitioners…
giuffre-maxwell
gov.uscourts.nysd.447706.139.0
7 pg
…Giuffre, by and through her undersigned counsel, respectfully submits
the following authority for the application of the privilege claimed regarding her in camera
submission, pursuant to the Court’s Order [DE 134] dated May 2, 2016.1
ARGUMENT
Statements made…
giuffre-maxwell
gov.uscourts.nysd.447706.542.5
11 pg
…3 and Jane Doe 4 as Petitioners (" Rule 15 Motion") ( DE
311). Both motions are ripe for review. For the following reasons, the Court concludes that they
should be denied.
I. Background
This is an action by two unnamed petitioners…
giuffre-maxwell
gov.uscourts.nysd.447706.1052.0
4 pg
…NY 10007
Re: Giuffre v. Maxwell,
Case No. 15-cv-7433-LAP
Dear Judge Preska,
The Original Parties jointly write to seek clarification of the following parts of the Protocol
for Unsealing Decided Motions, ECF No. 1044:
at a time…
giuffre-maxwell
gov.uscourts.nysd.447706.363.4
11 pg
…3 and Jane Doe 4 as Petitioners (“Rule 15 Motion”) (DE
311). Both motions are ripe for review. For the following reasons, the Court concludes that they
should be denied.
I. Background
This is an action by two unnamed petitioners…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.0
3 pg
…ECF No. 1230 at 3.
Plaintiff’s Position
On October 5, 2021, pursuant to the Court’s order, Plaintiff proposed via email that the
following eight non-party objectors that should be briefed first: Does 17, 53, 54, 55, 56…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.5
11 pg
…3 and Jane Doe 4 as Petitioners (“Rule 15 Motion”) (DE
311). Both motions are ripe for review. For the following reasons, the Court concludes that they
should be denied.
I. Background
This is an action by two unnamed petitioners…
giuffre-maxwell
gov.uscourts.nysd.447706.40.0
8 pg
…is attached in both a redlined version and a clean version (See McCawley Decl. at Exhibit 5),
addresses the following important issues:
Opening Paragraph: Given the fact that this case involves sexual abuse
allegations of a minor child, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…process and afford persons identified or otherwise interested in the
Sealed Materials the opportunity to participate in the Court’s individualized review, the Court
adopts the following protocol.
1. Non-Parties List: Plaintiff Virginia Giuffre and Defendant Ghislaine Maxwell
(collectively…
giuffre-maxwell
gov.uscourts.nysd.447706.1008.0
5 pg
…Cir. 2006) (holding that documents
submitted with a motion are “unquestionably judicial documents” “by virtue of having been
submitted to the court”). For the following reasons, the Court should hold that materials submitted
in support of motions are judicial documents…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.6
10 pg
…agencies, and after due comultation with the State
Attorney's Office; that the interests of the United States. the State of Florida, and tho
Defendant will be served by the following proccdurc;
THEREFORF., on the authority of R. Alexander Acosta…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.0
18 pg
…2020, I electronically served this Declaration of Laura A.
Menninger in Support of Ms. Maxwell’s Reply In Support of Her Objection to Unsealing Sealed
Material via ECF on the following:
Sigrid S. McCawley Paul G. Cassell
Meredith Schultz 383…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.1
4 pg
…process and afford persons identified or otherwise interested in the
Sealed Materials the opportunity to participate in the Court’s individualized review, the Court
adopts the following protocol.
1. Non-Parties List: Plaintiff Virginia Giuffre and Defendant Ghislaine Maxwell
(collectively…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.0
56 pg
…support of Ms. Maxwell’s Objections to Unsealing Sealed Materials Related to
Docket Entries 231, 279, 315, 320, & 335 via ECF on the following:
Sigrid S. McCawley Paul G. Cassell
Meredith Schultz 383 S. University Street
BOIES, SCHILLER & FLEXNER, LLP …
giuffre-maxwell
gov.uscourts.nysd.447706.1037.0
16 pg
…reflected in the attached redlined
version, are appropriate for the following reasons:
2(d): One or both of the Original Parties may want to oppose a Non-Party Objection
by arguing for un-sealing. Any argument by an Original Party…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.1
7 pg
…process and afford persons identified or otherwise interested in the
Sealed Materials the opportunity to participate in the Court’s individualized review, the Court
adopts the following protocol.
1. Non-Parties List: Plaintiff Virginia Giuffre and Defendant Ghislaine Maxwell
(collectively…
giuffre-maxwell
gov.uscourts.nysd.447706.997.0
5 pg
…the four-corners of Plaintiff’s own brief to see that.
Plaintiff cites for that bald proposition the following language (quoted here from
Plaintiff’s brief in its entirety): “‘Insofar as the District Court held that these materials are not…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.2
4 pg
…process and afford persons identified or
otherwise interested in the Sealed Materials the opportunity to participate in the Court’s
individualized review, the Court adopts the following protocol.
1. Non-Parties List: Plaintiff Virginia Giuffre and Defendant Ghislaine Maxwell
(collectively…