giuffre-maxwell
gov.uscourts.nysd.447706.1289.0
3 pg
…the Court to reconsider its unsealing order with respect to “13 of the 29 documents that
this Court unsealed,” based on her assertion that the Court’s ruling was somehow inconsistent with
its prior orders concerning other Non-Party Does…
giuffre-maxwell
gov.uscourts.nysd.447706.509.0
18 pg
…deliberately . According to Plaintiff,
the
Plaintiff made a deliberate
decision to
One can only assume then that contained the opposite: evidence unfavorable to
Plaintiff and inconsistent …
giuffre-maxwell
gov.uscourts.nysd.447706.1046.0
3 pg
…s approach would capture far fewer docket entries implicating Does 1 and
2, and is therefore inconsistent with the Court’s decision to proceed by non-party, as opposed to
by motion.1 It would also delay the unsealing process…
giuffre-maxwell
gov.uscourts.nysd.447706.1134.0_5
2 pg
…are
overbroad, and seek to obscure wide swaths of information in a manner wholly inconsistent with
this Court’s (and the Second Circuit’s) direction that any redactions be narrowly tailored.
1
Pursuant to the Court’s October 21, 2020…
giuffre-maxwell
gov.uscourts.nysd.447706.1123.0
2 pg
…the objection
(and non-objection) was lodged prior to receipt of the excerpts. Moreover, it is fundamentally
inconsistent to permit “unsealing” but keeping their names anonymous. Ms. Maxwell raised
some concerns about Doe 1 in the unredacted “Reply in Support…
giuffre-maxwell
gov.uscourts.nysd.447706.637.0
12 pg
…Generally, the work product privilege is waived when protected materials
are disclosed in a manner which is either inconsistent with maintaining secrecy against
opponents or substantially increases the opportunity for a potential adversary to obtain the
protected information.” Id. at…
giuffre-maxwell
gov.uscourts.nysd.447706.1052.0
4 pg
…on whether the names of two Does should be unsealed or unredacted in a
particular set of documents. That is inconsistent with Paragraph 2(j). And it could take years
before the Court could unseal even the First Five Motions.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1204.0
3 pg
…Ms. Maxwell’s narrow and
targeted request of this Court. For her part, plaintiff’s letter is patently inconsistent.
The stakes first. “No right ranks higher than the right of the accused to a fair trial.”
Press-Enter. Co. v…
giuffre-maxwell
gov.uscourts.nysd.447706.555.0
21 pg
…she had . decided to tell
I One can only assume then that Uiejoumal contained the opposite: evidence unfavorable to
Plaintiff and inconsistent with the story she ultimately submitted to the Court in the CVRA case.
I Presumably, the joumaf documented…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…2 did not even request excerpts of
the documents in which their names appear, let alone file objections to unsealing. Maxwell’s
objections are inconsistent with the Court’s May 1, 2020 Order, the presumption of public access
to documents…
giuffre-maxwell
gov.uscourts.nysd.447706.1125.0_2
5 pg
… For example, the September 25 Email is internally
inconsistent in that it purports not to object to unsealing but in
the same breath objects to the unsealing of the names of Does 1
and 2. This evinces a fundamental misunderstanding…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…Ms. Giuffre’s lawyers decided to treat her as a credible witness, and to accuse me of a heinous
crime on the basis of her inconsistent and incoherent testimony alone. I was the only
“academician” named as an abuser, despite…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…Giuffre with Dershowitz’s name in it.
7
Case 1:15-cv-07433-LAP Document 1328-41 Filed 01/05/24 Page 13 of 31
innocence. But this inference is inconsistent with Ms. Giuffre’s description of the manuscript…
giuffre-maxwell
gov.uscourts.nysd.447706.1069.0
25 pg
…Ms. Giuffre
9 would go forward in this case with Ms. Maxwell's deposition
10 transcript available to her while we must depose her anew
11 strikes me as inconsistent with the purpose of discovery,
12 fairness, due process, and…
giuffre-maxwell
gov.uscourts.nysd.447706.1067.0
10 pg
…C, D.
Further, Ms. Maxwell’s claim that the Court’s ruling on these documents is premature
because they name other third parties who have not yet received notice is inconsistent with the
Court’s note in Dkt. 1053. There…
giuffre-maxwell
gov.uscourts.nysd.447706.503.0
21 pg
…to "prove" an assertion about the
allegedly changing nature of a public "story." Similarly, to the
extent that the Joinder Motion is inconsistent with published
articles by Churcher, that would b e apparent from the face of
the Articles themselves…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…that their profession is the legal profession. Second, Edwards and Cassell
must establish the absence of any dispute that Dershowitz has imputed conduct inconsistent with
the proper exercise of their legal duties. And third, Edwards and Cassell must establish the…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
…Ms. Giuffre’s lawyers decided to treat her as a credible witness, and to accuse me of a heinous
crime on the basis of her inconsistent and incoherent testimony alone. I was the only
“academician” named as an abuser, despite…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.50
15 pg
…years after she had
drafted a supposedly comprehensive account of it—are a recent fabrication. Just as a prosecutor
would be bound to disclose such prior inconsistent statements by a complainant to the accused as
impeachment material, United States v…
giuffre-maxwell
gov.uscourts.nysd.447706.363.13
15 pg
…needed to “prove” an assertion about the allegedly changing nature of a public “story.”
Similarly, to the extent that the Joinder Motion is inconsistent with published articles by
Churcher, that would be apparent from the face of the articles themselves…
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