giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…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
…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…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…
giuffre-maxwell
1320-28
32 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.371.2
18 pg
…07433-LAP Document 371-2 Filed 08/12/16 Page 9 of 18
You or on which You hold a right or have held a right to withdraw funds at any time from
January 2015 to the present.
RESPONSE: Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1075.0
1 pg
…C
Laura A. Menninger
150 East 10th Avenue
Denver, Colorado 80203
…
giuffre-maxwell
gov.uscourts.nysd.447706.1034.0
16 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.185.4
10 pg
…Id.).
After considering the parties’ submissions and the proposed amended petition, the Court
finds that justice does not require amendment in this instance and exercises its discretion to deny
the amendment.
II. Discussion
“The decision whether to grant leave to…
giuffre-maxwell
gov.uscourts.nysd.447706.1122.0_2
13 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.542.5
11 pg
…Id.).
After considering the parties' submissions and the proposed amended petition, the Court
finds that justice does not require amendment in this instance and exercises its discretion to deny
the amendment.
II. Discussion
The decision wh…
giuffre-maxwell
gov.uscourts.nysd.447706.363.4
11 pg
…Id.).
After considering the parties’ submissions and the proposed amended petition, the Court
finds that justice does not require amendment in this instance and exercises its discretion to deny
the amendment.
II. Discussion
“The decision whether to grant leave to…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.5
11 pg
…Id.).
After considering the parties’ submissions and the proposed amended petition, the Court
finds that justice does not require amendment in this instance and exercises its discretion to deny
the amendment.
II. Discussion
“The decision whether to grant leave to…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1237.0
20 pg
…especially its allegations of sex trafficking of young girls, the Court
finds that any minor embarrassment or annoyance resulting from disclosure of Ms. Maxwell’s
mostly nontestimony about behavior that has been widely reported in the press is far outweighed…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.0
18 pg
…Id.).
After considering the parties’ submissions and the proposed amended petition, the Court
finds that justice does not require amendment in this instance and exercises its discretion to deny
the amendment.
II. Discussion
“The decision whether to grant leave to…
giuffre-maxwell
gov.uscourts.nysd.447706.1062.0
7 pg
…it is ironic that Dershowitz, by his motion, seeks to evade the protocol’s robust
individualized review that he finds lacking in the Protective Order.
4. Nature of the Reliance
Finally, courts examine the ways in which those from whom…
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…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. …
giuffre-maxwell
gov.uscourts.nysd.447706.406.0
31 pg
…Moreover, both the parties in this case have long reasonably relied on the existing Protective
Order.
If Dershowitz is permitted to cherry pick the documents
that he finds favorable and extract them from the protective order to serve his purposes…
giuffre-maxwell
gov.uscourts.nysd.447706.1113.0
7 pg
…Maxwell.
Second, and relatedly, the Court finds the gravity of the
privacy interests of nonparties--particularly nonparties who are
alleged victims of Jeffrey Epstein’s sexual abuse--weighs heavily
against the unilateral disclosure that Mr. Dershowitz seeks. Those
interests are…
giuffre-maxwell
gov.uscourts.nysd.447706.962.0
7 pg
…Partnership, 542
F.3d 43, 51 (2d Cir. 2008)). The Court sua sponte may impose Rule 11 sanctions or sanctions
pursuant to courts’ inherent power when it finds subjective bad faith. Muhammad v. Walmart
Stores E., L.P., 732 F…
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