giuffre-maxwell
gov.uscourts.nysd.447706.1105.0
8 pg
…no moment. No matter how many times they repackage the same
request, the Dershowitz parties are singularly ill-suited to guarding Maxwell non-party privacy
interests.
The Court should – indeed, for the reasons set forth previously by Your Honor, must…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…was arrested the
FBI spoke to a security guard who worked on the property who said that her brother had
hired him from a company staffed with former British military soldiers.
The filing states: 'The guard informed the FBI that…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.8
29 pg
…of electronically stored information or of
a responding party’s electronic information system may raise issues of confidentiality or
privacy…. Courts should guard against undue intrusiveness resulting from inspecting or testing
such systems.”), quoted with approval in Thompson v…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.13
22 pg
…For example, both the Coast Guard
and a seaman were found to have the same interest in asking questions about an incident at sea.
Id.
Similarly here, Epstein and Defendant had the same interest in asking questions about the
sex…
giuffre-maxwell
gov.uscourts.nysd.447706.1069.0
25 pg
…confidential status. So in my opinion, it appears the fox
16 would be guarding the henhouse with respect to whether these
17 materials remain confidential or don't.
18 And finally, I did not hear anything in Mr. Cooper's…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…B, 198:4-199:19.
e. There was no legitimate reason to attach Doe 1’s deposition to a garden-
variety request to exceed the presumptive 10-deposition limit. (CI-5 Improper submission
of papers).
f. Plaintiff repeatedly misstated Doe…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.22
22 pg
…jeffrey E.
Sent: Wednesday, January 21, 2015 4:47 PM
To: G Maxwell
Subject: Re: FW: Guardian
This will now end but I think a dismissive statement is ok
On Wednesday, January 21, 2015 , G Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.50
15 pg
…others. Her jealous guarding of
the Requested Documents is not motivated by any privacy interest she possesses in their
contents—she articulates none—but rather by a desire to avoid a full airing and robust discussion
of the actual facts…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.40
19 pg
…Andrew 'sex slave'
drama,” Daily Mail Online (Jan. 3, 2015).
e. “Court papers put daughter of Robert Maxwell at centre of ‘sex slave’
scandal,” The Guardian (Jan. 4, 2015).
f. “Prince Andrew denies sexual abuse allegations in unprecedented
Buckingham Palace…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.31
10 pg
…In a letter from Dershowitz to the Palm Beach police chief, obtained by The Guardian
(http://www.theguardian.com/us-news/2015/jan/08/alan-dershowitz-girl-jeffrey-epstein-teenager), Dershowitz attached a
copy of the girl’s MySpace page…
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…is whether intervention will unduly
delay or prejudice the adjudication of the rights of the parties
whose lawsuits are being 'invaded.’”).
Several other factors historically serve as guardrails for
the Court’s discretion in permitting intervention under Rule
24(b)…
giuffre-maxwell
1320-40
19 pg
…Andrew 'sex slave'
drama,” Daily Mail Online (Jan. 3, 2015).
e. “Court papers put daughter of Robert Maxwell at centre of ‘sex slave’
scandal,” The Guardian (Jan. 4, 2015).
f. “Prince Andrew denies sexual abuse allegations in unprecedented
Buckingham Palace…
giuffre-maxwell
gov.uscourts.nysd.447706.936.0
21 pg
…Nixon, 435 U.S. at
609. "The press does not simply publish information about trials but guards against the miscarriage
of justice by subjecting the police, prosecutors, and judicial processes to extensive public scrutiny
and criticism." Landmark Commc'ns, Inc…
giuffre-maxwell
gov.uscourts.nysd.447706.1182.0_1
3 pg
…unsealing. They are thus in a uniquely poor position to fill the
role of guardians of non-party privacy interests.
Case 1:15-cv-07433-LAP Document 1182 Filed 12/23/20 Page 3 of 3
December 23, 2020…
giuffre-maxwell
gov.uscourts.nysd.447706.1118.0
21 pg
…way for the Government to bypass
conducting its own discovery. The privacy interests this Court has guarded before still require
protection and should not be discarded merely for the Government’s convenience.
II. INTERVENTION IS IMPROPER FOR ACCESS TO SUMMARY…
giuffre-maxwell
gov.uscourts.nysd.447706.436.0
15 pg
…others. Her jealous guarding of
the Requested Documents is not motivated by any privacy interest she possesses in their
contents—she articulates none—but rather by a desire to avoid a full airing and robust discussion
of the actual facts…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.42
5 pg
…ESQUIRE
LEOPOLD KUVIN 20
20 2925 PGA Boulevard, Suite 200
Palm Beach Gardens, Florida 334 10
21
21 Phone: 561.5 15.1400 …
giuffre-maxwell
gov.uscourts.nysd.447706.55.21
69 pg
…2
3 LEOPOLD-KUVIN
4 JEFFREY EPSTEIN,
ADAM J. LANGINO, ESQ.
5 Defendant. 4 2925 PGA Boul…
giuffre-maxwell
gov.uscourts.nysd.447706.55.12
21 pg
…ESQUIRE
LEOPOLD KUVIN 20
20 2925 PGA Boulevard, Suite 200
Palm Beach Gardens, Florida 33410
21
21 Phone: 561.515.1400 …
giuffre-maxwell
gov.uscourts.nysd.447706.363.6
15 pg
…from responding to Request no. 25 in its entirety because on its face it seeks solely
privileged and confidential information relating to her retention of BSF.4 See Westco Inc. v. Scott
Lewis’ Gardening & Trimming, Inc., 26 So. 3d 620…
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