giuffre-maxwell
gov.uscourts.nysd.447706.1285.0
6 pg
…any details about her ordeals two decades
ago, she unquestionably continues to experience trauma similar to that of at least one
other Non-Party Doe whose privacy and identity this Court protected with Plaintiff
Virginia Guiffre’s consent. See Doc…
giuffre-maxwell
gov.uscourts.nysd.447706.1286.0
6 pg
…any details about her ordeals two decades
ago, she unquestionably continues to experience trauma similar to that of at least one
other Non-Party Doe whose privacy and identity this Court protected with Plaintiff
Virginia Guiffre’s consent. See Doc…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…4 So we are awaiting a ruling. We believe those
5 individuals should be protected under the Court's protective
6 order and those names kept confidential during the course of
7 this, and it is my understanding that defendants…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…communication.
13. Identify the basis, including all underlying facts, for your contention that Plaintiff’s
claims are barred because the statements made by Ms. Maxwell or her agent were
protected by the self-defense privilege.
ANSWER:
Ms. Maxwell objects to…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…one of the largest and
17 most significant pieces to us are the assertions by plaintiff
18 that her own communications with law enforcement are somehow
19 protected by --
20 THE COURT: I'm prepared to deal with that.
21 …
giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…conclusory remark does not negate the strong public interest in this action, and
it is not Plaintiff’s burden to identify why disclosure would serve the public interest—it is
presumed under the presumption of public access. See July 23…
giuffre-maxwell
gov.uscourts.nysd.447706.20.0
26 pg
…attention from her own conduct. Defendant’s main argument is that discovery should
be stayed because Defendant will be successful on her Motion to Dismiss as her defamatory
statements are protected by certain qualified privileges. The case law is clear…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.40
30 pg
…one of the largest and
17 most significant pieces to us are the assertions by plaintiff
18 that her own communications with law enforcement are somehow
19 protected by --
20 THE COURT: I'm prepared to deal with that.
21…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
… The Court of Appeals’ Stated Concern For The Publication Of Libelous
Statements Protected By The Litigation Privilege Emphasizes This Court’s
Responsibility To Protect The Interests Of Non-Parties.
While the Court of Appeals ultimately found Judge Sweet erred in…
giuffre-maxwell
gov.uscourts.nysd.447706.235.1
31 pg
…one of the largest and
17 most significant pieces to us are the assertions by plaintiff
18 that her own communications with law enforcement are somehow
19 protected by --
20 THE COURT: I'm prepared to deal with that.
21…
giuffre-maxwell
gov.uscourts.nysd.447706.136.0_2
29 pg
…one of the largest and
17 most significant pieces to us are the assertions by plaintiff
18 that her own communications with law enforcement are somehow
19 protected by --
20 THE COURT: I'm prepared to deal with that.
21 …
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…rendition of legal services by Edwards and
Cassell. As long as the Jane Doe #3 has a reasonable expectation of privacy in the
communication, under§ 90.507, the privilege is protected. Mcwatters v. Stale, 36 So.3d 613, 636
(Fla…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.22
22 pg
…r entification Information (Fingerprints, palm
Information
1'19.071 (2)(e) Confession
3€>!5.171 (15) Identity of 911 reports are confidential for period of 60 days after
seHvice
1 'I …
giuffre-maxwell
gov.uscourts.nysd.447706.1328.21
19 pg
…C entification Information (Fingerprints, palm
Information
C 1rn.071 (2)(e) Confession C ormants
C 3E>t,.171 (15) Identity of 911 re…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.16
22 pg
…1331.
2. Plaintiff files this Complaint under a pseudonym in order to protect
her identity because this Complaint makes allegations of a sensitive sexual nature
and disclosure of Plaintiffs name publicly will cause firther harm to her.
3. At all…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.8
16 pg
…another purpose, such as proving motive, opportunity, intent, preparation, plan,
knowledge, identity, absence of mistake, or lack of accident.”). Indeed, even more specifically
than the general provisions of Rule 404(b), Rule 415 makes these other acts admissible, due to…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.1
8 pg
…accused to make any statement;
(3) The performance of any examinations or tests or the accused’s refusal or failure to
submit to an examination or test;
(4) The identity, testimony or credibility of prospective witnesses, except that the lawyer…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.11
15 pg
…another purpose, such as proving motive, opportunity, intent, preparation, plan,
knowledge, identity, absence of mistake, or lack of accident.”). Indeed, even more specifically
than the general provisions of Rule 404(b), Rule 415 makes these other acts admissible, due to…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…they’ll 363-11
have to makeFiled
a claim08/11/16
that it was casePage
…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…Therefore, Ms. Giuffre is now required to take the deposition of pilot Dave
Rodgers to authenticate his pilot logs and the identity of the individuals on various flights.
In addition, as the Court knows, this case involves allegations that Ms…
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