…to “identify[] the most current address available for [a non-party] in a public records database or other readily available source.” This will ensure that the notice to non- parties is “the best practicable under the circumstances.” Guevoura Fund Ltd…
…S. Currency in the Amount of $119,984.00, 304 F.3d 165, 176-77 (2d Cir. 2002)); N.Y. Dist. Council of Carpenters Pension Fund v. Perimeter Interiors, Inc., 657 F. Supp. 2d 410, 415 (S.D.N.Y…
…8 Brink’s Inc. v. City of New York, 717 F.2d 700 (2d Cir. 1983)........................................................................................................ 8 Cerro Gordo Charity v. Fireman’s Fund Am. Life Ins. Co., 819 F.2d 1471 (8th Cir. 1987) .........................................................................…
…undue burden (“Privacy Interests”). CI-4 - Preserving the fundamental rights of suspects or others under criminal investigation – including due process right to a fair trial and impartial jury unimpaired by excessive publicity, release of potentially inadmissible evidence for the Criminal…
… Annoyance, embarrassment, oppression, undue burden (“Privacy Interests”) (“CI- 3”). 4. Preserving the fundamental rights of suspects or others under criminal investigation (“CI-4”). 5. Improper submission of documents thereby weaponizing judicial documents (“CI- …
…letter. It appears now that Defendant, at least, recognizes the fundamental problem under the common law right of access and the First Amendment in sealing any portion of the summary judgment argument. And, Plaintiff has now revealed in her letter…
…undue burden (“Privacy Interests”). CI-4 - Preserving the fundamental rights of suspects or others under criminal investigation – including due process right to a fair trial and impartial jury unimpaired by excessive publicity, release of potentially inadmissible evidence for the Criminal…
…created and directed the companies whose aircraft transported the young women and girls, owned and maintained the secluded islands to which they were transported, and provided sources of funding for this activity.” (USVI Reply Br. at 3 (citing CICO Compl. …
…a crime victim. Plaintiff and Ms. Maxwell have a fundamental difference in the approach to identifying the non-parties who should be on the list. Plaintiff takes the position that if a non-party’s name has appeared anywhere in…
…Not Warrant Continued Sealing. Finally, Maxwell cites the countervailing interest of “[p]reserving the fundamental rights of suspects or others under criminal investigation” as justifying complete sealing of any document containing portions or summaries of her deposition testimony. Maxwell Mem…
…behavior that I abhor and have never ever been party to, witness to events that I have never seen, living off trust funds that I have never ever had, party to stories that have changed materially both in time place…
…same breath objects to the unsealing of the names of Does 1 and 2. This evinces a fundamental misunderstanding about the process at hand--after all, an objection by Does 1 and 2 to the release of their names is…
…It would be fundamentally unfair to allow Giuffre to continue to press these allegations where she and her attorneys have had the full benefit of discovery already conducted concerning these allegations which is in her possession and which is being…
…insure their irrelevance.” United States v. Amodeo, 71 F.3d 1044, 1049 (2d Cir. 1995) (“Amodeo II”); United States v. All Funds on Deposit at Wells Fargo Bank, 643 F. Supp. 2d 577, 583 (S.D.N.Y. 2009). “Especially …
…n.42. G. Preserving the fundamental rights of suspects or others under criminal investigation. The preservation of the fundamental rights of suspects and others under criminal investigation is a powerful countervailing interest weighing against the presumption of access. See Nixon…
…Kingdom.” Resp. at 3. This argument is fundamentally flawed for five reasons. First, the very news articles cited by Plaintiff document that the townhome had been on the market for sale for over a year - i.e., since at least…
…this point, there can be little dispute: Mr. Dershowitz has effectively distilled his request down to a narrower set of documents that target – with pinpoint accuracy – fundamental non-party privacy interests. See DE 153 (Dershowitz) at 3 (requesting, among other…
…is seeking to drain funds from the very estate that should be paying the Epstein victims’ claims...We view her actions as unconscionable but this is an individual who lost sight of right from wrong a very long time ago…
…to obtain interrogatory requests and responses, expert reports, or deposition transcripts. See id. EPDM underscores the fundamental problem with Mr. Dershowitz’s indiscriminate request for all discovery materials in this case. Notwithstanding factual overlap, he is defending against a substantially…
…this Court to decide whether the seal should be removed. The case law makes this clear and this very subject was extensively debated and resolved prior to the issuance of the Protocol. More fundamentally, there is a substantial difference between…