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.447706.824.0_2
47 pg
…any identifying information, for example, their Social Security
21 number or an address be able to be protected for those that are
22 coming to testify. I know that makes it a little bit more
23 difficult, but if we…
giuffre-maxwell
gov.uscourts.nysd.447706.46.0
22 pg
… Defendant’s Communication with Attorneys Philip Barden, Mark Cohen, and Brett
Jaffe Are Protected by the Attorney-Client Communication Privilege (Entries 1, 2, 9
and 17) ………………………………………
giuffre-maxwell
gov.uscourts.nysd.447706.148.0
9 pg
…publicly disclosed volumes of information related to her
allegations, to claim that letters or emails from her lawyers or other documents sent to any law
enforcement agency are protected by any privilege. Plaintiff lacks standing to raise the issue and
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…those events is protected from disclosure by law. Florida
statutes protect “[a]ny information in a videotaped statement of a minor who is alleged to be or
who is a victim of sexual battery . . . which reveals that minor’s identity.”…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.1_1
13 pg
…Many of them also concern minors and a victim of sexual assault; therefore, they are
protected by various state statutes. Ms. Giuffre requests that this Court maintain the confidentiality
designations over these police reports and direct the Defendant to disclose…
giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
… Intervenors’ First Proposition of Law: For minor victims of sexual abuse, “redactions
should be applied sparingly to shield only information that would identify those who
have not already been publicly identified.” DE 1248, at 2.
The Reality: Courts routinely seal…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.18
50 pg
…This
Court’s Order ............................................................................................23
5. Information About Ms. Giuffre’s Sexual Abuse is Protected by
Florida Statutes ..................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1122.0_2
13 pg
…on the subject matter in question.
The second circumstance establishing a compelling need for the USVI to gain access
through modification of the Protective Order is that even the identity of the deponent witnesses is
not known or otherwise knowable…
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.447706.1312.0
9 pg
…review of
each document and to: (1) evaluate the weight of the presumption of public access to the materials;
(2) identify and evaluate the weight of any countervailing interests; and (3) determine whether the
countervailing interests rebut the presumption.” Jan…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.28
24 pg
…serving party tangible things in a manner that, without revealing information itself
may move the court for the district where compliance is required for an privileged or protected, will enable the parties to assess the claim.
order compelling production or…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…affirmed by the Second Circuit, found that Ms. Maxwell
failed to identify deposition testimony that “constitute[] personal information which might lead
to annoyance or embarrassment if unsealed” because, inter alia, she “refused to testify as to any
consensual adult activity…
giuffre-maxwell
gov.uscourts.nysd.447706.503.0
21 pg
…III. The Applicable Standard
Pursuant to Federal Rule of Civil Procedure 4 5 ( c) ( 3) (A), a
court "must quash or modify a subpoena that (iii) requires
disclosure of privileged or other protected matter, if no
exception or waiver applies…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.32
27 pg
…information itself
(ii) These acts may be required only as directed in the order, and the privileged or protected, will enable the parties to assess the claim.
order must protect a person who is neither a party nor a party…
giuffre-maxwell
gov.uscourts.nysd.447706.223.1
14 pg
…These aul, may be reqllired only as directed in the order, und lhe privileged or protected, will enable the parties to assess ille claim.
order mllst protect a person who is neither II pHny nor a party'~ "metr tiol!…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.33
24 pg
…For other providers, no records were produced. Where no
documents were produced, Plaintiff failed to identify the dates and nature of the treatment
received, as requested in the Interrogatory. Id. Plaintiff failed therein to identify any treatment
providers prior to…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.1_2
24 pg
…each category of damages claimed by
the disclosing party—who must also make available for inspection and copying as under Rule 34 the
documents or other evidentiary material, unless privileged or protected from disclosure, on which each
computation is based…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.4
40 pg
…4 Filed 01/05/24 Page 5 of 40
that Ms. Maxwell has published “numerous” false statements, yet Plaintiff stubbornly refuses to
identify each of these allegedly false statements. Interrogatory No. 6 asked simply that for each
allegedly false statement…