giuffre-maxwell
gov.uscourts.nysd.447706.1010.0
3 pg
…parties’ counsel conduct
a review of the sealed and redacted materials, confer and inform the Court by letter
about the identity of non-parties identified in the material, and confer and inform the
Court by letter of any material in…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…Court of the 15th Cir. for Palm Beach County) ("Epstein v. Edwards"). The
Supplemental responses also identified the pleadings, discovery responses and depositions in
twenty-four civil proceedings in which Dersbowitz's client, Jeffrey Epstein, is named as a party…
giuffre-maxwell
gov.uscourts.nysd.447706.24.0
4 pg
…Clerk of Court by using the CM/ECF system. I also certify that the foregoing
document is being served this day on the individuals identified below via transmission of Notices of
Electronic Filing generated by CM/ECF.
Laura A. Menninger…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…a) the weight of presumption of public access that should be afforded to the
document, (b) the identification and weight of any countervailing interests supporting continued
sealing/redaction, and (c) whether the countervailing interests rebut the presumption of public
access…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…plainly unreasonable.
Finally, it bears emphasizing that virtually all of the prominent individuals accused by
Giuffre concerning whom Dershowitz seeks discovery have already been publicly identified by
name in deposition testimony which has been unsealed in Maxwell. See Exhibit A…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.27
11 pg
…served on plaintiff’s counsel Ms. Maxwell’s Initial Fed. R.
Civ. P. 26(a)(1)(A) Disclosures. The third-listed individual we identified who “likely [has]
discoverable information” was Philip Barden, who, we disclosed, had information “concerning
press statements . . …
giuffre-maxwell
gov.uscourts.nysd.447706.1240.0
5 pg
…810
F. Supp. 2d 616, 621–22 (S.D.N.Y. 2011). Those factors and the harm of disclosure must be
identified with specificity. Lytle, 810 F. Supp. 2d at 621–22.
As set forth below, the Does have failed…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…trial. Ms. Maxwell’s responses to Plaintiff’s Interrogatories
are based on information currently known to her and are given without waiving Ms. Maxwell’s
right to use evidence of any subsequently discovered or identified facts, documents or
communications. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1289.0
3 pg
…motion also does not directly address the Court’s sound and obvious reason for unsealing,
which is that numerous public sources, including a federal complaint she herself voluntarily filed,
have already identified her, and described her relationship with Jeffrey Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…here will unfairly prejudice Ms.
Maxwell’s rights to a fair trial by poisoning any venire and influencing witness testimony. For
reasons discussed below, the Court should decline to unseal the identified Sealed Items.
I. Ms. Maxwell’s July 22…
giuffre-maxwell
gov.uscourts.nysd.447706.1062.0
7 pg
…Rejecting Dershowitz’s position, the Court specifically structured the protocol to afford
notice to those persons identified or otherwise interested in the Sealed Documents and to allow
such affected persons the opportunity to object and be heard. As made clear…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.1
4 pg
…a) the weight of presumption of public access that should be afforded to the
document, (b) the identification and weight of any countervailing interests supporting continued
sealing/redaction, and (c) whether the countervailing interests rebut the presumption of public
access…
giuffre-maxwell
gov.uscourts.nysd.447706.34.0
3 pg
…Clerk of Court by using the CM/ECF system. I also certify that the foregoing
document is being served this day on the individuals identified below via transmission of Notices
of Electronic Filing generated by CM/ECF.
Laura A. Menninger…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.4
23 pg
…Clerk of Court by using the CM/ECF system. I also certify that the foregoing
document is being served this day on the individuals identified below via transmission of Notices
of Electronic Filing generated by CM/ECF.
Laura A. Menninger…
giuffre-maxwell
gov.uscourts.nysd.447706.39.1
7 pg
…7. Documents are designated as CONFIDENTIAL by placing or affixing on them
(in a manner that will not interfere with their legibility) the following or other
appropriate notice: “CONFIDENTIAL.” Discovery material designated
CONFIDENTIAL shall be identified by Bates number. To…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.0
16 pg
…are advised in their Objection to Un-Sealing at ¶ 2 that they
“understand this Objection will be filed under seal and I will not be identified in any court
filing.” Ms. Maxwell remains concerned that Non-Parties will be reluctant…
giuffre-maxwell
gov.uscourts.nysd.447706.858.0
3 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only
and is not intended to imply institutional endorsement by the University of Utah for this private
representation.
2…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.1
7 pg
…a) the weight of presumption of public access that should be afforded to the
document, (b) the identification and weight of any countervailing interests supporting continued
sealing/redaction, and (c) whether the countervailing interests rebut the presumption of public
access…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…weight of
presumption of public access that should be afforded to an item, (b) the identification and weight
of any countervailing interests supporting continued sealing/redaction of the item, and (c) whether
the countervailing interests rebut the presumption of public…
giuffre-maxwell
gov.uscourts.nysd.447706.201.0
5 pg
… Case 1:15-cv-07433-RWS Document 201 Filed 06/13/16 Page 2 of 5
identified individuals who may have relevant information about the matters at issue in this case.
Certain of those individuals have been the subject…
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