giuffre-maxwell
gov.uscourts.nysd.447706.1327.18
5 pg
…cv-07433-LAP Document 1327-18 Filed 01/05/24 Page 2 of 5
Search Terms Defendant Has Already Searched
From Plaintiff’s June 30th proposed list:
(note: Plaintiff’s numbers have been used)
1) jef*
2) geof*
3) epst…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…Dec. 16,
2019 (DE 1016). Such materials are referred to herein as the “Sealed Materials” or “Sealed
Items.” The Sealed Materials will be enumerated in a List of Decided Motions designated by the
Court. In accordance with Brown v. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1046.0
3 pg
…multiple times to propose five motions pertaining to J. Doe 1 and J. Doe 2, as
identified on the sealed Non-Party List, with which the Court may begin administering the Order
and Protocol for Unsealing Decided Motions, Dkt. 1044…
giuffre-maxwell
gov.uscourts.nysd.447706.1258.0
3 pg
…and unredacted any and all documents that identify the men who abused the girls trafficked
by Jeffrey Epstein and Defendant Maxwell (“the Epstein Client List”).
Sealing those documents violates the rights of the press and of the people at large…
giuffre-maxwell
gov.uscourts.nysd.447706.1269.0
1 pg
…[email protected], is to be
removed as counsel of record within the ECF system and removed from the list of attorneys to
receive electronic filings in this case.
10th day of _____________________,
This _____ August 2022.
_____________…
giuffre-maxwell
gov.uscourts.nysd.447706.1032.0
1 pg
…No. 15 Civ. 7433 (LAP)
Dear Judge Preska:
Attached please find Ms. Maxwell’s List of Decided Motions, including in the last
column those exhibits and deposition page numbers previously released by the 2nd Circuit.
With this list, Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1329.0
3 pg
…For the reasons set forth below, the letter-motions
to unseal docket entry 1026-3 are DENIED.
First, docket entry 1026-3 is not an accurate list of
non-party names. Since this filing, the parties have provided the
Court…
giuffre-maxwell
gov.uscourts.nysd.447706.1034.0
16 pg
…nos. 468, 567) were actually decided by Judge Sweet and
thus disagreed as to whether they should be included on the
list of materials to be reviewed by the Court. After
reviewing those items, the Court determines that they were…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.15
5 pg
…The
representations in the Response are perplexing, particularly in light of the below email communication in which I
specifically 1) informed you of the search terms that we would run derived from your list, and 2) specifically requested a
telephone…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.12
11 pg
…Court Order regarding
Forensic Examination of Devices, as follows:
INTRODUCTION
Defense counsel has already run the amended list of search terms proposed by Plaintiff
on each applicable device and as to each email account to which Ms. Maxwell has access…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.1
4 pg
…16,
2019 (DE 1016). Such materials are referred to herein as the “Sealed Materials” or “Sealed
Item.” The Sealed Materials will be enumerated in a List of Decided Motions designated by the
Court .1 In accordance with Brown v. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1038.0
2 pg
…agrees to the
Court’s Protocol as written, including the Court’s proposal to review documents by Non-Party in
the order that the Non-Parties are listed on the Non-Party list. Defendant has proposed a number
of changes…
giuffre-maxwell
gov.uscourts.nysd.447706.41.5
18 pg
…or information which will improperly annoy,
embarrass, or oppress any party, witness, or person providing discovery in this case,
Purposes And Limitations Formatted: List Paragraph, Indent: First line:
…
giuffre-maxwell
gov.uscourts.nysd.447706.1029.0
2 pg
…this Court has determined that it will review in
the first instance those motions that were decided by Judge Sweet. Both parties submitted lists of
decided motions to this Court, but Defendant’s list excluded two of those decided motions…
giuffre-maxwell
gov.uscourts.nysd.447706.1321.0
2 pg
…this matter. It lists all the non-parties listed in any of the originally sealed
documents and was used by the Court to manage the unsealing process and make its
determinations about what information was to be unsealed. It is…
giuffre-maxwell
gov.uscourts.nysd.447706.1049.0
91 pg
…LAP)
-against-
ORDER
GHISLAINE MAXWELL,
Defendant.
LORETTA A. PRESKA, Senior United States District Judge:
The Court has reviewed and approved the parties’ joint proposed
redacted Decided Motions List that was submitted to the Court on
April 3, 2020. (See dkt…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.6
5 pg
…runarenot“ secret” and notselected by thedefense– they are“ therem ainderoftheterm s” notspecifically discussed
inthebelow em ail.Foravoidanceofdoubt,itisyourproposed list,excluding item s49,50,51,64,66-72,93-94,113,
114-116,119-120,121-122,124-341,355,358…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.1
7 pg
…Dec. 16,
2019 (DE 1016). Such materials are referred to herein as the “Sealed Materials” or “Sealed
Items.” The Sealed Materials will be enumerated in a List of Decided Motions designated by the
Court . In accordance with Brown v. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.2
4 pg
…materials are referred to herein as the “Sealed Materials” or “Sealed
Item.” The Sealed Materials are will be enumerated in the a List of Decided Motions designated
by the Court (Doc.1007-1) approved by the Court on January 16…
giuffre-maxwell
gov.uscourts.nysd.447706.1028.0
5 pg
…No. 15 Civ. 7433 (LAP)
Dear Judge Preska:
I am writing in response to plaintiff’s counsel’s January 30 letter, which concerns
three matters: the List of Decided Motions, the Non-Party List, and Ms. Maxwell’s
proposed Order…
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