giuffre-maxwell
gov.uscourts.nysd.447706.962.0
7 pg
…Order.
INTRODUCTION
The Protective Order requires the destruction or return of all “Confidential”-designated
materials. This action was terminated more than eighteen months ago when the parties reached a
settlement and stipulated to dismissal, and the Court dismissed the case…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…client’s allegations that Dershowitz had sexual relations with her
when she was a minor. Settlement talks in the defamation case have been going on for months,
and the two sides just reached agreement.
Shortly before 5 p.m. today…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…In fact, for the most part, her failures to actively
pursue depositions with these witnesses qualifies as in-excusable neglect: She frittered away
seven of the eight months of the discovery period and now has placed Ms. Maxwell, this Court…
giuffre-maxwell
gov.uscourts.nysd.447706.89.0
10 pg
…admission pro hac vice appear to be inaccurate, this consolidated reply is
being filed to clarify a few points of law and fact.
II. ARGUMENT
For many months now, Professor Cassell and Mr. Edwards have actively worked to help
represent…
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…id. ¶¶ 5(a)-(h)).
The protective order has been a primary theater of battle in
this litigation over the past several months.1 Most notably, it
has been the subject of two separate requests seeking modification
brought by Alan Dershowitz…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.0
9 pg
…There are new, intervening and significant facts since briefing closed on the first round
of review of sealed materials. After many months of relentless negative media coverage of
Mr. Epstein and allegations that Ms. Maxwell was involved in his criminal…
giuffre-maxwell
gov.uscourts.nysd.447706.408.0
13 pg
…2014, despite having had four months to provide a
position, the Government responded by email to counsel that it was seeking more time,
indicating that the Government understood that victims’ counsel might need to file a motion with
the court…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…In fact, for the most part, her failures to actively
pursue depositions with these witnesses qualifies as in-excusable neglect: She frittered away
seven of the eight months of the discovery period and now has placed Ms. Maxwell, this Court…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.13
22 pg
…in United States v. Miller, the Court ruled that the government could subpoena
an individual’s bank records, including several months of canceled checks, deposit slips, and
monthly statements. The Court explained that because the checks were “not confidential
communications…
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.447706.1069.0
25 pg
…are under seal, but
17 what this all tells us, Judge, and all the complexity and the
18 months your Honor has spent fashioning the protocol, is that
19 your Honor should deny this motion, deny it now, deny
20…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…for sale for over a year - i.e., since at least April of 2015, over six months before
Plaintiff filed this lawsuit. See http://nypost.com/2016/04/28/alleged-epstein-madam-sells-16m-
manhattan-townhouse/ (last accessed Aug. 29…
giuffre-maxwell
gov.uscourts.nysd.447706.1071.0
13 pg
…interests of judicial economy because it would threaten to undercut
the ongoing unsealing process in Maxwell. The Court spent months,
with substantial input from the parties, fashioning a procedure
for unsealing the Maxwell filings that properly takes into account
the…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.0
35 pg
…the common law and the First Amendment.”). Given Judge
Nathan’s ability to remedy any bad pretrial publicity through the voir dire process (which will not
commence for another eight months), Maxwell’s speculative concerns about her right to a…
giuffre-maxwell
gov.uscourts.nysd.447706.1213.0
18 pg
…that there are 185
Non-Parties on the Non-Party list, and only two of the 185 Non-Parties’ documents have been
addressed after more than eight months of briefing, the unsealing process is likely to take several
years and…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.1_1
7 pg
…98 Line No. 16
Change to: “As you can see in that answer I’m not even sure. It wasn’t six months, but
between six months and a year which is why I’m saying nine months. It was…
giuffre-maxwell
gov.uscourts.nysd.447706.96.0
15 pg
…in Defendant’s view, the only remaining
volume of documents she would be required to produce – other than the two initial documents she
produced -- is approximately “50” pages of documents that presumably date from the last 18 months. Of
course…
giuffre-maxwell
gov.uscourts.nysd.447706.406.0
31 pg
…2016, “[u]pon a showing of good cause,” the Protective Order was entered (DE 62 at p.1). The
following month,
Furthermore, as this Court will remember,
23
“Did Dershowitz Shell Out Big Bucks to Get Settlement in Sex Case…
giuffre-maxwell
gov.uscourts.nysd.447706.604.0
11 pg
…2008). In what appears to have been a sweetheart deal, Epstein was only given an 18-month
sentence and served but 13 months. See “High-profile cases: Crimes that shook Palm Beach through the decades”,
Palm Beach Daily News (Feb…
giuffre-maxwell
gov.uscourts.nysd.447706.1226.0
4 pg
…The parties and non-parties should not be permitted to delay the process by
the submission of memoranda that were due over six months ago.
Case 1:15-cv-07433-LAP Document 1226 Filed 08/04/21 Page 3…
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