giuffre-maxwell
gov.uscourts.nysd.447706.604.0
11 pg
…Court suspending the First
Amendment right of access). Mr. Cernovich’s journalistic focus is on Maxwell and in reporting
on Jeffrey Epstein’s accusations.2 In fact, in the 2016 presidential election, Epstein’s activities
were the focus of political…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.27
11 pg
…generally id., Ex.K. He did disclose his intent and strategy underlying his
preparation of the statement he caused to be transmitted January 2, 2015, via press agent Ross
1111
Gow to various journalists. See id., Ex.K ¶¶ 12-24…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…Sharon Churcher, Plaintiff’s friend, advocate and former journalist with the
Daily Mail, who filed a Motion to Quash her subpoena on the day before her scheduled
deposition,2 and (2) Plaintiff, who refused to answer questions at her deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.17
13 pg
…1979))). Mr. Dershowitz filed an
appeal (Doc.504), which is pending.
In January 2017 a purported journalist Michael Cernovich requested unsealing of
Ms. Maxwell’s summary judgment brief, her attorney’s declaration in support of the summary
judgment motion, and…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…Sharon Churcher, Plaintiff’s friend, advocate and former journalist with the
Daily Mail, who filed a Motion to Quash her subpoena on the day before her scheduled
deposition,2 and (2) Plaintiff, who refused to answer questions at her deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…the accusations against him. On January 19, 2017, Cernovich, an
independent blogger and self‐described “popular political
journalist,”7 moved to intervene, seeking to unseal the summary
judgment record, and Dershowitz joined his motion. On April 6, 2018,
after the…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…26/18
08/27/18 Page
Page 64 of
of 43
41
Sweet, D.J.
Third-party proposed intervenors The Miami Hera…
giuffre-maxwell
1320-28
32 pg
…Sharon Churcher, Plaintiff’s friend, advocate and former journalist with the
Daily Mail, who filed a Motion to Quash her subpoena on the day before her scheduled
deposition,2 and (2) Plaintiff, who refused to answer questions at her deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.10
64 pg
… This has been in the media. So my client
8 is just another journalist looking to find out here what's
9 going on.
10 Honestly, I am litigating a little bit with one arm
11 tied behind my back…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…the accusations against him. On January 19, 2017, Cernovich, an
independent blogger and self‐described “popular political
journalist,”7 moved to intervene, seeking to unseal the summary
judgment record, and Dershowitz joined his motion. On April 6, 2018,
after the…
giuffre-maxwell
gov.uscourts.nysd.447706.957.0
13 pg
…1979))). Mr. Dershowitz filed an
appeal (Doc.504), which is pending.
In January 2017 a purported journalist Michael Cernovich requested unsealing of
Ms. Maxwell’s summary judgment brief, her attorney’s declaration in support of the summary
judgment motion, and…
giuffre-maxwell
gov.uscourts.nysd.447706.978.0
27 pg
…the accusations against him. On January 19, 2017, Cernovich, an
independent blogger and self‐described “popular political
journalist,”7 moved to intervene, seeking to unseal the summary
judgment record, and Dershowitz joined his motion. On April 6, 2018,
after the…
giuffre-maxwell
gov.uscourts.nysd.447706.936.0
21 pg
…the Miami Herald Media
Company (the "Miami Herald"), and Julie Brown, investigative journalist for the Miami Herald
("Julie Brown" and together with Miami Herald, the "Intervenors"), respectfully submit this
memorandum of law in support of their motion to intervene and…
giuffre-maxwell
gov.uscourts.nysd.447706.589.0
24 pg
…seeking substantially the same relief.
Proposed Intervenor and purported “journalist” Michael Cernovich requests that this
Court grant him intervenor status for the purpose of unsealing and publishing a single filing from
the above-captioned case: Defendant’s Motion for Summary…
giuffre-maxwell
gov.uscourts.nysd.447706.702.0
63 pg
… This has been in the media. So my client
8 is just another journalist looking to find out here what's
9 going on.
10 Honestly, I am litigating a little bit with one arm
11 tied behind my back…
giuffre-maxwell
gov.uscourts.nysd.447706.977.0
27 pg
…the accusations against him. On January 19, 2017, Cernovich, an
independent blogger and self‐described “popular political
journalist,”7 moved to intervene, seeking to unseal the summary
judgment record, and Dershowitz joined his motion. On April 6, 2018,
after the…
giuffre-maxwell
gov.uscourts.nysd.447706.436.0
15 pg
…a reporter neither implicates any privilege nor justifies
confidentiality protections. The Emails are in Ms. Giuffre’s possession and were produced by Ms. Giuffre—not a
journalist—in discovery. New York’s shield law, Civil Rights Law § 79-h(c)…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…to
testify at a deposition in a civil action and produce documents (the “Subpoena”) in this case.
PRELIMINARY STATEMENT
Sharon Churcher’s involvement in this defamation case stems entirely from the fact that,
in her capacity as a professional journalist…
giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…ready to pounce with voice recorders and cameras in hand. In recent months,
journalists have searched high and low for Maxwell, who had already been
maintaining a low profile even before the Epstein scandal came roaring back to life
this…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…history on a number of
occasions, including during her interviews with ABC, with other media outlets, with book
authors and journalists, but chose not to tell her true story, instead telling falsehoods and
fabricated and mistaken events, dates and participants.
…