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.447706.364.0
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.447706.946.0_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.447706.994.0
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.447706.1328.9
21 pg
…186 (S.D.N.Y. 2014) (citations, internal quotation
marks and brackets omitted).
Defendant has submitted that she has not put her private
affairs at issue, and that such questions are highly intrusive.
Notwithstanding, the questions are directed to reveal…
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.447706.637.0
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.447706.542.8
4 pg
…educational purposes including, for such purposes, the making of distributions to organizations that qualify as exempt
organizations under section 501( c)( 3) of the Internal Revenue Code, or the corresponding section of any future federal tax
code. The corporation is…
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.447706.1250.0
7 pg
…Warner Commc’ns, Inc., 435 U.S. 589, 598 (1978) (internal quotation marks omitted).
In support of their claim that “there is no basis” to continue respecting the privacy rights
of an “already . . . disclosed” victim’s identity and circumstances, id…
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.447706.928.0
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.447706.1304.0
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.447706.34.2
3 pg
…UHNWIs on reputational issues
Skills
Public Relations Marketing Communications Change Management
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Event Management Media Relations I…
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