giuffre-maxwell
gov.uscourts.nysd.447706.1218.13
15 pg
…all controversial. For example, a
police beat reporter may be the one to inform a department source about a pending internal affairs investigation, in
order to enable the source to investigate the situation and report back to the journalist. Thus…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…N.Y. 2003) (internal quotation marks and alteration omitted).
“It is well-settled that intervention pursuant to Rule 24(b) is the proper procedure for a
third party to seek to modify a protective order in a private suit.” Id. …
giuffre-maxwell
gov.uscourts.nysd.447706.364.0
32 pg
…N.Y. 2003) (internal quotation marks and alteration omitted).
“It is well-settled that intervention pursuant to Rule 24(b) is the proper procedure for a
third party to seek to modify a protective order in a private suit.” Id. …
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.447706.1328.6
32 pg
…N.Y. 2003) (internal quotation marks and alteration omitted).
“It is well-settled that intervention pursuant to Rule 24(b) is the proper procedure for a
third party to seek to modify a protective order in a private suit.” Id. …
giuffre-maxwell
gov.uscourts.nysd.447706.1256.7
14 pg
…However, your
13 own experts, cocounsel and staff may have
limited internal use of same with the
14 understanding that we agree to destroy your
realtime rough draft and/or any computerized
15 form, if any, and replace it with…
giuffre-maxwell
gov.uscourts.nysd.447706.57.1
26 pg
…occurred was that on the day of the
accident a brief report was made to the railway inspectorate,
soon afterwards a joint internal report (" the joint inquiry
report") was prepared incorporating statements of witnesses,
which was also sent to the…
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.447706.1247.0
25 pg
…363-7, and 423-4.
5
Case 1:15-cv-07433-LAP Document 1247 Filed 03/18/22 Page 10 of 25
3d 161, 169 (S.D.N.Y. 2018) (internal quotation marks, alterations, and omitted); In re Parmalat…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…of justice.” 524 U.S. at 403 (internal quotation marks omitted).
In setting out the legal standards pertaining to waiver of attorney-client privilege,
Defendant fails to cite the controlling – and protective – law on the issue. In a federal case,
…
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.447706.1296.2
17 pg
…testimony that it sought. The court must determine the propriety of the deponent's
objection to answering the questions, and can order the deponent to provide improperly withheld
answers during a continued deposition” (internal citations omitted)). Of course, the party
…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…testimony that it sought. The court must determine the propriety of the deponent's
objection to answering the questions, and can order the deponent to provide improperly withheld
answers during a continued deposition” (internal citations omitted)). Of course, the party
…
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.0
35 pg
…19, 2020) (internal quotation marks
and alterations omitted).
Similarly, Maxwell’s claim that certain Non-Parties may be witnesses in her criminal trial
has no bearing on whether the public has a right to access a judicial document filed in…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.3
21 pg
…very specifically on these
communications in her (currently-pending) summary judgment motion. Here again, some
highlight will serve to illustrate the point (internal citations to Barden Declaration omitted and
emphasis added):
! Consistent with Mr. Barden’s purposes for the statement…
giuffre-maxwell
gov.uscourts.nysd.447706.356.0
17 pg
…testimony that it sought. The court must determine the propriety of the deponent's
objection to answering the questions, and can order the deponent to provide improperly withheld
answers during a continued deposition” (internal citations omitted)). Of course, the party
…
giuffre-maxwell
gov.uscourts.nysd.447706.68.0
17 pg
…the plaintiff can show no actual damages at all, a plaintiff who has otherwise
shown defamation may recover at least nominal damages,’” and confirming an award of punitive
damages) (internal citation omitted). “In assessing the amount of damages to award…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…2002) (internal citations omitted).
The mandate rule bars disclosure of any pages that were redacted by the Second Circuit.
The law of the case doctrine bars disclosure of any other “deposition responses concerning
intimate matters where the questions were likely…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…testimony that it sought. The court must determine the propriety of the deponent's
objection to answering the questions, and can order the deponent to provide improperly withheld
answers during a continued deposition” (internal citations omitted)). Of course, the party
…