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.447706.1219.30
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.447706.1218.14
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.447706.955.0
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.447706.1328.6
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.447706.994.0
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.447706.57.1
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.447706.1211.0_1
5 pg
…Supp. 2d 678, 695 (S.D.N.Y. 2011)
(citation and internal quotation marks omitted). Such motions
“are properly granted only if there is a showing of: (1) an
intervening change in controlling law; (2) the availability of
new evidence…
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.447706.599.0
12 pg
…Schneider,
379 F. Supp. 2d 461 (S.D.N.Y. 2005)......................................................................................... 3
Statutes
IRC §170......................................................................................................................................... 6
§501(c)(3) of the Internal Revenue C…
giuffre-maxwell
gov.uscourts.nysd.447706.1304.0
3 pg
…. offered no more than generalized concerns of adverse publicity.” Doe 107 Br. at 2, 20.
(internal quotation marks omitted). We assume the parties’ familiarity with the underlying facts, the
procedural history of the case, and the issues on appeal.
“In…
giuffre-maxwell
gov.uscourts.nysd.447706.193.0
14 pg
…tradition that everyone should have his own day in court.”
Richards, 517 U.S. at 798 (internal quotation marks omitted). Indicating the strength of
that tradition, we have often repeated the general rule that “one is not bound by a
…
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.447706.1303.0
3 pg
…. offered no more than generalized concerns of adverse publicity.” Doe 107 Br. at 2, 20.
(internal quotation marks omitted). We assume the parties’ familiarity with the underlying facts, the
procedural history of the case, and the issues on appeal.
“In…
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.447706.1068.0
31 pg
…2d 383, 387 (E.D.N.Y. 2013) (internal quotation marks and citations
omitted); see also Amodeo II, 71 F.3d at 1051 (“[A] court may consider whether the nature of the
materials is such that there is a fair…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…1993 WL 525114, at *1 (S.D.N.Y. 1993) (internal citations omitted). The Defendant’s
continued systemic foot-dragging and obstructionism – even following the Court’s June 20
Sealed Order and August 10, 2016 Order [DE 352] – makes an…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.18
11 pg
…Apr. 2, 2009)
(internal quotations omitted).
3
Rule 26(b)(1) has since been modified to read “(i) the discovery sought is unreasonably cumulative or duplicative,
or can be obtained from some other source that is more convenient, less burdensome…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…plane with Mr. Epstein and other individuals. See Cassell Decl. ¶ 21(g)
(internal parentheses omitted). What his declaration conveniently fails to mention is that the
flight in question took place on November 17, 2005, years after Ms. Giuffre’s association…
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