gov.uscourts.nysd.447706.1049.0.pdf PDF
…in support of 12.1.15 Defendant's Motion to Dismiss 16‐1 Exhibit A‐E 12.1.15 Plaintiff's Memorandum of 23 Law in Opposition of 12.17.15 Defendant's Motion to Dismiss Declaration of Sigrid McCawley …
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for “motion to dismiss”
in 407ms
gov.uscourts.nysd.447706.1204.0.pdf PDF
…Six, and # 6 Motion Under the Fourth Amendment, Martindell, and the Fifth Amendment to Suppress All Evidence Obtained from the Government’s Subpoena to [Redacted] and to Dismiss Counts Five and Six). Last night, the government responded to Ms. Maxwell…
gov.uscourts.nysd.447706.892.0.pdf PDF
…with the motion of defendant Ghislaine Maxwell (" Maxwell " or the "Defendant") for summary judgment to dismiss the complaint of plaintiff Virginia L . Giuffre ("Giuffre" or the "P l aintiff"). Based upon the conclusions set forth below , the motion to intervene…
gov.uscourts.nysd.447706.1335.5.pdf PDF
…that, as things stand today, all of this testimony is under 3 Id. Ms. Giuffre will be filing an opposition to Dershowitz’s motion to intervene shortly. 4 See McCawley Decl. at Composite Exhibit 1, Figueroa June 24, 2016 Dep…
gov.uscourts.nysd.447706.1057.0.pdf PDF
…solely to five-year-old discovery disputes and therefore, at most, begin with a presumption of public access “somewhat lower than the presumption applied to material introduced at trial, or in connection with dispositive motions such as motions for dismissal…
gov.uscourts.nysd.447706.1166.0_1.pdf PDF
…501, 510 (1984)). Plaintiff ignores this expressly-condoned countervailing factor and instead relies on cases generally concerning pretrial publicity and motions to transfer venue.4 Plaintiff shrugs off concerns about the fairness of Ms. Maxwell’s criminal trial as “vague…
gov.uscourts.nysd.447706.949.0.pdf PDF
…12 We've also asked for, because we don't know exactly 13 what else is in the record, for things like motions to compel 14 or motions for a protective order, the other side of that. Not 15 knowing…
gov.uscourts.nysd.447706.1351.0.pdf PDF
…Methodology Orders and to hold Cigna in contempt and impose sanctions.” Id. at 246. After that motion was denied, Amara sought to appeal “from both the Methodology Orders and the Sanctions Order.” Id. at 246–47. In dismissing that part…
gov.uscourts.nysd.447706.980.0.pdf PDF
…in filings submitted in connection with discovery disputes or motions in limine is generally somewhat lower than the presumption applied to material introduced at trial, or in connection with dispositive motions such as motions for dismissal or summary judgment.” Id…
gov.uscourts.nysd.447706.1134.0_5.pdf PDF
…should have done so already, and cannot use vague allusions to “additional information” as a basis for seeking judicial relief. In any event, the Second Circuit has already rejected this argument in dismissing Maxwell’s criminal appeal, holding that, “as…
gov.uscourts.nysd.447706.1156.0.pdf PDF
…the first set of motions the Court reviewed. Giuffre v. Maxwell, 827 F. App’x 144 (2d Cir. 2020). The Second Circuit found that the Court “correctly held that the deposition materials are judicial documents to which the presumption of…
gov.uscourts.nysd.447706.1253.0.pdf PDF
…dispositive motions such as motions for dismissal or summary judgment.’” Doe 144 Apr. 8, 2022, Obj. at 2 (internal citation omitted). The Second Circuit has held, however, that “[m]aterials submitted in connection with, and relevant to, discovery motions, motions…
gov.uscourts.nysd.447706.1328.20.pdf PDF
…Id. B. Plaintiff’s Counsel Has Repeatedly and Publicly Filed In This Case Numerous Publicly Available Police Reports With Redacted Juvenile Information In complete contradiction to her legal position in this Motion, Plaintiff and her counsel have repeatedly filed in…
gov.uscourts.nysd.447706.991.1.pdf PDF
…48 DECLARATION of Laura A. Menninger in Support re: 164 Motion to Compel MOTION to Compel all Attorney-Client Communications 06/06/2016 194 and Work Product Put At Issue by Plainti…
gov.uscourts.nysd.447706.896.0.pdf PDF
…on April 20, 2017, I electronically served this Defendant’s Renewed Motion to Compel Non-Party Witness to Respond to Deposition Questions and Complete Search of ESI via ECF on the following: Sigrid S. McCawley Paul G. Cassell Meredith Schultz…
gov.uscourts.nysd.447706.1199.6_1.pdf PDF
…Id. B. Plaintiff’s Counsel Has Repeatedly and Publicly Filed In This Case Numerous Publicly Available Police Reports With Redacted Juvenile Information In complete contradiction to her legal position in this Motion, Plaintiff and her counsel have repeatedly filed in…
gov.uscourts.nysd.447706.1199.16_1.pdf PDF
…instant motion. Instead, Defendant says that the police report documenting Ms. Giuffre’s rape while a minor has her name redacted. Of course, such a redaction does Ms. Giuffre little good when Defendant and her cohorts distribute it to the…
gov.uscourts.nysd.447706.885.0.pdf PDF
…cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF MS. GIUFFRE’S MOTION TO EXCLUDE PHILIP BARDEN FROM TESTIFYING AT TRIAL, TO EXCLUDE DEFENSES BASED UPON CERTAIN DOCUMENTS AND TO EXCLUDE THEIR PRESENTATION AT TRIAL, FOR AN ADVERSE INFERENCE JURY INSTRUCTION…
gov.uscourts.nysd.447706.1213.1.pdf PDF
…to object to 398-5 unsealing has not yet expired. The Original Parties sent the Non- Party deponent (Doe 7) notice of unsealing, and the Non-Party deponent did not request excerpts. 356: Plaintiff's Motion to Direct Defendant to…
gov.uscourts.nysd.447706.1148.0.pdf PDF
…states: Whenever a party seeks to file any document or material containing CONFIDENTIAL INFORMATION with the Court in this matter, it shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules…
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