giuffre-maxwell
gov.uscourts.nysd.447706.1320.17
25 pg
…Court or any Orders of the Court.
3. Ms. Maxwell objects to the Requests to the extent they seek documents or
information protected by the attorney/client privilege, the work-product doctrine, Rule 408 of the
Federal Rules of Evidence…
giuffre-maxwell
1320-17
25 pg
…Court or any Orders of the Court.
3. Ms. Maxwell objects to the Requests to the extent they seek documents or
information protected by the attorney/client privilege, the work-product doctrine, Rule 408 of the
Federal Rules of Evidence…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…Law ................................................................ 7
B. All of the Information Sought by the Subpoena Is, At a Minimum,
Protected by the Qualified Privilege Under the Shield Law ....................... 9
1. The Info…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…the subpoena served on Ms. Ransome seeks documents that are wholly
irrelevant to the underlying action including protected financial information and documents or
communications between Sarah Ransome and her attorneys, which are protected by the attorney-
client privilege and the…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…the subpoena served on Ms. Ransome seeks documents that are wholly
irrelevant to the underlying action including protected financial information and documents or
communications between Sarah Ransome and her attorneys, which are protected by the attorney-
client privilege and the…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…opinion, the Second Circuit suggested in dicta that “[t]he District Court may also
order the parties to identify and notify additional parties whose privacy interests would likely be
1
Based on lessons learned from past rounds of unsealing, the…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…the subpoena served on Ms. Ransome seeks documents that are wholly
irrelevant to the underlying action including protected financial information and documents or
communications between Sarah Ransome and her attorneys, which are protected by the attorney-
client privilege and the…
giuffre-maxwell
gov.uscourts.nysd.447706.371.2
18 pg
…Court or any Orders of the Court.
3. Ms. Maxwell objects to the Requests to the extent they seek documents or
information protected by the attorney/client privilege, the work-product doctrine, Rule 408 of the
Federal Rules of Evidence…
giuffre-maxwell
gov.uscourts.nysd.447706.994.0
14 pg
…presumption of access to these documents, the Court should also find that Ms.
Maxwell and J. Doe have failed to identify any non-generalized, non-speculative interest that
would outweigh these First Amendment and common law rights of access. Therefore…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…information itself
(ii) These acts may be reqtJired only as directed in the order, and the privileged or protected, will enable the parties to asses.~ the claim.
order must protect a person who is neither a party nor a…
giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…under Rule 26.3(c)(7), Southern District of New York Local Civil Rules.
8. “Identify” (with respect to persons) incorporates the definition as set forth in Rule
26.3(c)(3), Southern District of New York Local Rules. Therefore…
giuffre-maxwell
gov.uscourts.nysd.447706.1123.0
2 pg
…days of service of the Excerpts, the Non-Party may submit
to the Court an objection.” Any such “objection” must “state briefly the reasons for the
objection and identify any countervailing interest that militates against unsealing.” Id. Then,
“[w]ithin…
giuffre-maxwell
gov.uscourts.nysd.447706.57.3
39 pg
…that civil and criminal proceedings might
be brought against them and that the dominant purpose of the investigations
was to identify the causes of the explosion so that their solicitors could provide
legal advice in connection with the expected proceedings…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.33
12 pg
…Giuffre of any
practical ability to use the discovery, and, importantly, it was incumbent on Defendant to identify
this account.
The Second Circuit has stated, “[w]here documents, witnesses, or information of any
kind relevant issues in litigation is or…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…Giuffre of any
practical ability to use the discovery, and, importantly, it was incumbent on Defendant to identify
this account.
The Second Circuit has stated, “[w]here documents, witnesses, or information of any
kind relevant issues in litigation is or…
giuffre-maxwell
gov.uscourts.nysd.447706.468.0
12 pg
…Giuffre of any
practical ability to use the discovery, and, importantly, it was incumbent on Defendant to identify
this account.
The Second Circuit has stated, “[w]here documents, witnesses, or information of any
kind relevant issues in litigation is or…