giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…or, at a Minimum, After Determination of Summary
Judgment Motion ................................................................................................................. 7
B. Scope of Financial Discovery Must Be Limited to Least Invasion of Private Financial
Affairs, i.e., a Sworn Net Worth Affidavit ...…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…functioning as surrogates for the
public.” Brown, supra at 53 (internal quotation marks and citations omitted).
Part of TGP’s mission is conducting investigative journalism in pursuit of an open
government. The sealing of documents that might identify Epstein’s…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…dissenting) ("Those who
wrote the Bill of Rights believed that every individual needs
both to communicate with others and to keep his affairs to
15
Case 1:15-cv-07433-RWS
Case 1:15-cv-07433-LAP Document
Document…
giuffre-maxwell
gov.uscourts.nysd.447706.946.0_1
14 pg
…See United States v. Amodeo, 71 F.3d 1044, 1047 (2d Cir. 1995)
("Amodeo II") (a report determined to be a judicial document was "presumptively subject to public
inspection") (internal quotation marks omitted); Bernsten v. O'Reilly, No. 17 CIV…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…permitting
redaction of the names of two women with whom the defendant had allegedly had extramarital
affairs, despite the fact that – in the court’s view – the women were “not entirely innocent
third parties.”) (internal quotation omitted).
As the Third…
giuffre-maxwell
gov.uscourts.nysd.447706.551.0
17 pg
…United States v. Amodeo II, 71 F.3d 1044,
1048 (2d Cir. 1995)) (internal quotation marks omitted).
2.1.2 The First Amendment Compels Access
The First Amendment requires public access to court proceedings. See Press-Enter. Co. v.
Superior…
giuffre-maxwell
gov.uscourts.nysd.447706.994.0
14 pg
…For example, in Amodeo II, the court states
“financial records of a wholly owned business, family affairs, illnesses, embarrassing conduct with
no public ramifications” may be considered private information. If a privacy interest is involved,
then the Court must balance…
giuffre-maxwell
gov.uscourts.nysd.447706.637.0
12 pg
…12
Specifically,
Ms. Giuffre, hereby moves this Court to Order Defendant to produce all work product documents
(including any internal e-mail communications) and all attorney-client communications she has
had with her attorney, Philip Barden, …
giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…929 F.3d 41, 51 (2d
Cir. 2019) (internal quotations omitted), all in service of the next lawsuit against yet another
prominent person with deep pockets.
Ms. Maxwell—and likely all the non-parties who participate in this sealing-unsealing…
giuffre-maxwell
gov.uscourts.nysd.447706.1059.0
3 pg
…or the need to correct a clear error or prevent
manifest injustice.” United States v. Thorn, 446 F.3d 378, 383 (2d Cir. 2006) (internal
quotations omitted), quoted in United States v. Barnett, Nos. 90-cr-913 & 19-cv-132…
giuffre-maxwell
gov.uscourts.nysd.447706.928.0
11 pg
…‘the Court must limit its
analysis to the four corners of the complaint.’” (internal citations omitted)).
3
Case 1:15-cv-07433-LAP Document 928 Filed 10/19/17 Page 4 of 11
4
Case 1:15-cv-07433-LAP…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.19
12 pg
…Specifically,
Ms. Giuffre, hereby moves this Court to Order Defendant to produce all work product documents
(including any internal e-mail communications) and all attorney-client communications she has
had with her attorney, Philip Barden, relating to his representation of…
giuffre-maxwell
gov.uscourts.nysd.447706.610.0
3 pg
…but did not, are just as deserving of disclosure as those that actually entered into the judge's
decision.” Id. at 124 (internal quotation marks and ellipsis omitted).
Ultimately, “summary judgment is an adjudication, and an adjudication is a formal…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…v. Ganim, 269 F. Supp. 2d 6, 8 (D. Conn. 2002) (internal citation omitted).
District courts in this Circuit have permitted government actors to intervene in civil
actions. See Twenty First Century Corp. v. LaBianca, 801 F. Supp. 1007, 1009…
giuffre-maxwell
gov.uscourts.nysd.447706.1302.0
3 pg
…E-
Com. Ltd., 880 F.3d 620, 627 (2d Cir. 2018) (internal quotation marks and citation omitted).
Timeliness is a “threshold consideration under Rule 24(b).” United States v. Pitney Bowes, Inc.,
25 F.3d 66, 74 (2d Cir. 1994…
giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…. . should weigh heavily in a court’s
balancing equation”) (internal quotations omitted).
B. “Ancillary” court submissions. A court’s authority to oversee discovery and control
the evidence introduced at trial is ancillary to the court’s core role in adjudicating…
giuffre-maxwell
gov.uscourts.nysd.447706.1126.0
3 pg
…Klipsch Grp. Inc. v. Epro E-Commerce Ltd., 880 F.3d 620,
627 (2018) (internal quotation marks omitted).
Although Michael Cernovich, DBA Cernovich Media, did not enter an appearance in this
1
appeal, letters of his dated July 31, 2020…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…accusations against
him. The pact came with a statement from former FBI director Louis Freeh, who said he conducted an
internal investigation into the accusations against Dershowitz but that “the totality of the evidence” refuted
the claims. Yet, Dershowitz has…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.17
13 pg
…media campaign to make public a selected portion of the discovery in this
action to defend himself not in this court but in the court of public opinion.” Id. 21 (internal
quotations and citation omitted). If his motion were granted…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.15
11 pg
…in deciding such a motion to dismiss, ‘the Court must limit its
analysis to the four corners of the complaint.’” (internal citations omitted)). Yet the Epstein
Defendants seek to intervene in this case for the exact purpose of obtaining relief…
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