giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…Of course, such a redaction does Ms. Giuffre little good when
Defendant and her cohorts distribute it to the press - the identity of the victim in the police report
will presumably be supplied by Defendant. Indeed, Defendant and/or her…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.1
13 pg
…
m. When Rodriguez was arrested by the FBI trying to sell Epstein’s “little black
book” of contacts and phone numbers, he appeared to have circled the name
of Alan Dershowitz as someone who had information about Epstein criminal
activities…
giuffre-maxwell
gov.uscourts.nysd.447706.1204.0
3 pg
…Maxwell when, as here, the presumption of access to a judicial
document is at its lowest, amounting to “little more than a prediction of public access absent a
countervailing reason.” Brown v. Maxwell, 929 F.3d 41, 49–50 (2d…
giuffre-maxwell
gov.uscourts.nysd.447706.1254.0
18 pg
…20 Attorneys for Miami Herald Media Co. and Julie Brown
BY: CYNTHIA GIERHART
21
22 DYKEMA GOSSETT, PLLC
Attorneys for Doe 17
23 BY: BECKY JAMES
24
TALKIN MUCCIGROSSO & ROBERTS, LLP
25 Attorneys for Doe 73
BY: DENIS P. KELLEHER…
giuffre-maxwell
gov.uscourts.nysd.447706.1196.0
32 pg
…Maxwell's
11 observation of the general media coverage of the unsealing
12 process does little to show how the unsealing of any specific
13 information at issue in the current round of unsealing will
14 jeopardize her right to…
giuffre-maxwell
gov.uscourts.nysd.447706.1050.0
12 pg
…stands right now, a Non-Party
18 has 14 days from service, which could mean as little as ten
19 days when they get a legal notice out of the blue. Right now,
20 given what's happening, people have…
giuffre-maxwell
gov.uscourts.nysd.447706.1021.0
18 pg
…of that to the
15 Court in about two weeks.
16 The most time-consuming piece is the deposition
17 transcripts so that will take us a little bit longer but that
18 would be at least give the Court…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.0
18 pg
…P. 12(f).
Petitioners’ Rule 21 Motion consists of relatively little argumentation regarding why the
Court should permit them to join in this action: they argue that (1) they were sexually abused by
1
The Court notes that, regardless of…
giuffre-maxwell
gov.uscourts.nysd.447706.1062.0
7 pg
…terms of the Maxwell Protective Order, that condition would afford little protection here –
where Dershowitz has consistently and adamantly opposed confidentiality and pressed his
dispute with Giuffre through out-of-court public declarations.
Indeed, Dershowitz apparently has already evinced an…
giuffre-maxwell
gov.uscourts.nysd.447706.1067.0
10 pg
…unreliable, and incorrect. Again, Ms. Maxwell offers little support for those
conclusions, relying on hearsay requirements found in the Federal Rules of Evidence.4 This
argument conflates the admissibility requirements and sealing requirements. See Burton v.
Zwicker & Assocs., No. CV…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…a negligible
role in the performance of Article III duties” are accorded only a low
presumption that “amounts to little more than a prediction of public
access absent a countervailing reason.”30 Documents that are never
filed with the court…
giuffre-maxwell
gov.uscourts.nysd.447706.185.4
10 pg
…P. 12(f).
Petitioners’ Rule 21 Motion consists of relatively little argumentation regarding why the
Court should permit them to join in this action: they argue that (1) they were sexually abused by
1
The Court notes that, regardless of…
giuffre-maxwell
gov.uscourts.nysd.447706.946.0_1
14 pg
…Filed 05/04/18 Page 7 of 14
matters of clear public interest and give the public the opportunity to learn more about how wealthy
and powerful men are able to act as sexual predators with little or no consequence.
…
giuffre-maxwell
gov.uscourts.nysd.447706.542.5
11 pg
…Civ. P. 12( f).
Petitioners' Rule 21 Motion consists of relatively little argumentation regarding why the
Court should permit them to join in this action. they argue that ( 1) they were sexually abused by
The Court notes that, regardless of…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…a negligible
role in the performance of Article III duties” are accorded only a low
presumption that “amounts to little more than a prediction of public
access absent a countervailing reason.”30 Documents that are never
filed with the court…
giuffre-maxwell
gov.uscourts.nysd.447706.978.0
27 pg
…a negligible
role in the performance of Article III duties” are accorded only a low
presumption that “amounts to little more than a prediction of public
access absent a countervailing reason.”30 Documents that are never
filed with the court…
giuffre-maxwell
gov.uscourts.nysd.447706.363.4
11 pg
…P. 12(f).
Petitioners’ Rule 21 Motion consists of relatively little argumentation regarding why the
Court should permit them to join in this action: they argue that (1) they were sexually abused by
1
The Court notes that, regardless of…
giuffre-maxwell
gov.uscourts.nysd.447706.977.0
27 pg
…a negligible
role in the performance of Article III duties” are accorded only a low
presumption that “amounts to little more than a prediction of public
access absent a countervailing reason.”30 Documents that are never
filed with the court…
giuffre-maxwell
gov.uscourts.nysd.447706.1228.0
4 pg
…Sealed Records are equal for this analysis, and
there are many documents where the presumption of access “amounts to little more than a
prediction of public access absent a countervailing reason,” as the Second Circuit has observed.
Brown v. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.5
11 pg
…P. 12(f).
Petitioners’ Rule 21 Motion consists of relatively little argumentation regarding why the
Court should permit them to join in this action: they argue that (1) they were sexually abused by
1
The Court notes that, regardless of…