giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…Filed 08/11/16 Page 3 of 40
The defamation case filed against Dershowitz by two other prominent members of the legal
community, highprofile Florida lawyer Brad Edwards and former federal judge Paul Cassell,
just settled. As you may recall…
giuffre-maxwell
gov.uscourts.nysd.447706.1010.0
3 pg
…be accomplished through briefing, with evidentiary support.
Since the Court is requesting that the reason be provided in a letter, we want to assume
the Court is contemplating the former and not the latter, i.e., the Court is not…
giuffre-maxwell
gov.uscourts.nysd.447706.958.3
4 pg
…Giuffre (including Messrs.
Cassell and Pottinger, along with Boies, Schiller and the firm formerly known
as Farmer, Jaffe).
With respect to deposition transcripts, the party who noticed the deposition
(all of which were designated CONFIDENTIAL) will undertake to obtain…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…Sharon Churcher, Plaintiff’s friend, advocate and former journalist with the
Daily Mail, who filed a Motion to Quash her subpoena on the day before her scheduled
deposition,2 and (2) Plaintiff, who refused to answer questions at her deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.13
22 pg
…concurring). It thus “protects two different interests of the citizen—the interest in retaining
possession of property and the interest in maintaining personal privacy.” Id. (cleaned up). “A
seizure threatens the former, a search the latter.” Id. Like a search…
giuffre-maxwell
gov.uscourts.nysd.447706.1105.0
8 pg
…Mr. Dershowitz apparently share is their
desire to make the entirety of this matter public.
If one former party in Maxwell and a new party in Dershowitz – a totally different case –
could simply agree to modify the Protective Order, it…
giuffre-maxwell
gov.uscourts.nysd.447706.1071.0
13 pg
…Giuffre, Cooper
& Kirk, had received from Ms. Giuffre’s former counsel, Boies
Schiller Flexner,3 the Maxwell materials at issue in their
entirety. Asked to explain how those materials came into the
firm’s possession, attorneys from Cooper & Kirk explained…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.4_1
4 pg
…Giuffre's minor children.
Fourth, the police reports that show photographs of Ms. Giuffre's former home also
implicate her privacy interests, and therefore should remain outside of the public realm.
Fifth, police records concerning alleged crimes committed by Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
…21 the judge down there's order, she claimed to have been involved
22 in sexual relations with Prince Andrew, with world leaders, a
23 former prime minister of some country or other, Mr. Alan
24 Dershowitz. She made a…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…in
attempting to provide adequate notice to the Non-Parties. See DE 1154 (detailing issues).
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…Sharon Churcher, Plaintiff’s friend, advocate and former journalist with the
Daily Mail, who filed a Motion to Quash her subpoena on the day before her scheduled
deposition,2 and (2) Plaintiff, who refused to answer questions at her deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…shadows outside of the normal sunlight of transparency and accessibility. The public
has a right to know who trafficked these girls.
The former judge assigned to this case committed a transgression, shielding from scrutiny
that which rightfully should be exposed…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…2. While we appreciate the views
expressed in Judge Pooler’s separate opinion, the panel majority believes that the
efforts invested by three former district judges in reviewing these materials
adequately address those concerns.
23 Nixon, 435 U.S. at…
giuffre-maxwell
gov.uscourts.nysd.447706.96.0
15 pg
…she would not produce any
additional documents until the Court ruled at the April 21, 2016 hearing on the Motion to Appear
Pro Hac Vice of former federal Judge Paul Cassell, and Co-Counsel Brad Edwards’ filings.
Defendant’s position…
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…and depose those individuals in due course.
there--access to a sealed envelope purportedly containing
instructions from the former judge (who had also died since the
judgment) regarding what to do in the event that the fraudster
returned to the…
giuffre-maxwell
gov.uscourts.nysd.447706.149.0
9 pg
…Conduit, a former United States Congressman brought a
defamation action against a media commentator based on statements made regarding the
disappearance and death of a Washington intern. The defendant filed a motion to compel the
plaintiff to provide deposition testimony…
giuffre-maxwell
gov.uscourts.nysd.447706.23.0
32 pg
…Defendant had done to her, prompting a broadside of attacks earlier this year from the
1
Ms. Giuffre is represented in the CVRA case by a former Federal Judge for the District of Utah, Paul Cassell, and a
victim’s…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.0
9 pg
…2020, the Court said it was “troubled” to learn that plaintiff’s
successor counsel, Cooper & Kirk, had received from plaintiff’s former counsel, Boies Schiller
Flexner, various discovery materials that were subject to the Protective Order. Doc.1071 at 4…
giuffre-maxwell
1320-28
32 pg
…Sharon Churcher, Plaintiff’s friend, advocate and former journalist with the
Daily Mail, who filed a Motion to Quash her subpoena on the day before her scheduled
deposition,2 and (2) Plaintiff, who refused to answer questions at her deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…2016). And some will never have that opportunity, as
is the case with former Massachusetts Institute of Technology professor Marvin Minsky, who
was recently implicated in the Epstein matter when the summary judgment materials were
publicly released. More than 350…
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