giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…Ghislaine Maxwell, March 2, 20161
Less than six months after representing to this Court that this case involves “highly
personal and sensitive information” warranting a broad protective order, Defendant now wants to
publicize police reports concerning Ms. Giuffre - most of…
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…that addressing all remaining objections at once would be unduly burdensome. As an initial matter,
the Court should deny Maxwell’s de facto application for a five-month stay, and require her to
demonstrate good cause to justify any further…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…Ghislaine Maxwell, March 2, 20161
Less than six months after representing to this Court that this case involves “highly
personal and sensitive information” warranting a broad protective order, Defendant now wants to
publicize police reports concerning Ms. Giuffre - most of…
giuffre-maxwell
gov.uscourts.nysd.447706.148.0
9 pg
…ARGUMENT
I. PLAINTIFF’S VIOLATION OF THIS COURT’S ORDER TO PRODUCE
DOCUMENTS IS NOT AN OPPORTUNITY FOR HER TO RE-LITIGATE
THE ISSUE.
Plaintiff has been attempting to dodge the production of these documents for months.
First, Plaintiff claimed…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…Plaintiff’s sworn testimony that she ran away
from home at the age of 13, lived on the street for “months” without word from
her family, and ultimately was rescued by the FBI in a SWAT raid from the
clutches…
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.447706.1196.0
32 pg
…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 a fair trial that is likely many months
15 away…
giuffre-maxwell
gov.uscourts.nysd.447706.1099.0
4 pg
…filing her most
recent appeal. Maxwell also had ample opportunity to negotiate for the inclusion of such a one-
week appeal window in the Protocol when the parties were negotiating the Protocol many months
ago, yet failed to do so…
giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…among others, that: (1) the government did not move to seal the state-court
records until they had already been publicly available on the federal docket for eight months; (2) the government
made a conclusory claim that mere redactions were…
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.447706.276.0_1
35 pg
…Churcher has continued to cover this story as
9 a reporter, has published stories, including just I think two
10 months ago, often using "Virginia" or her so-called agents as
11 sources, of course most prominently in early 2015…
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1351.0
32 pg
…See In re Wild, 994 F.3d at 1249. Maxwell stood trial, was found guilty by a
jury, and sentenced to a term of 240 months’ incarceration, which she is presently
serving. See United States v. Maxwell, 118 F.4th…
giuffre-maxwell
gov.uscourts.nysd.447706.1052.0
4 pg
…Motions should be
unsealed before moving onto the next five. The public has a presumptive right to access these
documents. The Second Circuit remanded this matter nearly 10 months ago. Plaintiff therefore
contends that, despite the burdens of this process…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.6_1
14 pg
…as addressed more fully below, defense counsel never acquiesced to her request and she
failed to pursue a judicial determination of the matter until August 8, 2016, nearly three months
later, thus, Plaintiff has waived any claim of confidentiality.
I. …
giuffre-maxwell
gov.uscourts.nysd.447706.551.0
17 pg
…at ¶ 4. His Twitter account, in which he reports on news and provides opinion,
has nearly 200,000 followers and reaches millions monthly. See id. at ¶ 8.
Part of Cernovich Media’s mission is conducting investigative journalism in pursuit of…
giuffre-maxwell
gov.uscourts.nysd.447706.892.0
11 pg
…2016), the Court only allowed
intervention "[after parties settled the action" - not one month
prior to the commencement of trial. This action is currently
scheduled for trial in mid-May and a release of contested
confidential discovery materials could conceivably…
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