giuffre-maxwell
gov.uscourts.nysd.447706.1226.0
4 pg
…given that the public identification of a stated objection, a
geographical location (such as in an address), or even the non-party’s legal counsel (if she or he
has one) could disclose the identity of the objecting non-party…
giuffre-maxwell
gov.uscourts.nysd.447706.892.0
11 pg
…giving rise to this defamation action . Among the
statements at issue are a l legations of sexua l abuse of minors .
Discovery has proceeded i nvolving these issues and those persons
alleged l y involved .
II . The Protective Order
The…
giuffre-maxwell
gov.uscourts.nysd.447706.1182.0_1
3 pg
…As such, the Dershowitz Protective Order may fatally undermine this Court’s carefully
constructed measures designed to protect from unnecessary public disclosure sensitive and
private non-party information in the Maxwell materials.
After rejecting multiple attempts by Mr. Dershowitz to…
giuffre-maxwell
gov.uscourts.nysd.447706.1045.0
2 pg
…cv-07433-LAP Document 1045 Filed 04/03/20 Page 2 of 2
Honorable Loretta A. Preska
April 3, 2020
Page 2
confusion and backtracking to re-consider motions and exhibits multiple times. Ms. Maxwell
opposes Plaintiff’s planned sequence.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…as to each document for ease of reference. In future oppositions to
objections to unsealing, Plaintiff will refer back to relevant portions of this brief instead of
re-briefing issues multiple times. Further, Plaintiff files this brief with the same…
giuffre-maxwell
gov.uscourts.nysd.447706.1196.0
32 pg
…I will ask my law clerk,
20 Patrick Malone, to interrupt if I am misreading any of this.
21 As you can see, the parties' chart is enormous and has
22 multiple, multiple iterations of findings listed on it. If…
giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…identity of any victim of a sex offense . . . shall
be confidential.” Intervenors do not cite the facts from Thomas indicating that the government’s motion to seal was
deficient for multiple reasons, including, among others, that: (1) the government did…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
… We have
19 also been unable to access that. It appears that it still
20 exists, but despite multiple and diligent attempts to get into
21 that account, we have been unable to. And I have been involved
22 in…
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…Maxwell for nearly six years have two
other major, multiple-week trials scheduled for almost the entirety of September and October 2021.
Practically speaking, the entire Maxwell team have scant time outside of a courtroom in the coming
months and…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…and defame Ms. Giuffre.
The Court is aware that a mountain of testimonial evidence, from multiple witnesses,
firmly establishes Defendant operated as convicted pedophile Jeffrey Epstein’s procurer of
underage girls. The Court is also aware that, as things stand…
giuffre-maxwell
gov.uscourts.nysd.447706.1010.0
3 pg
…of times we must perform the analysis and carry
that burden. There will be times when there are multiple grounds to maintain the seal
of a single document or to maintain the redaction of words, sentences or paragraphs
within it…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…pages of Palm Beach Police Reports, some redacted, some unredacted, with multiple
references to Non-Party Does. Exhibit 4 and 7 are inadmissible hearsay transcripts from an
unreliable deceased individual never deposed by Ms. Maxwell. Exhibits 5 and 6 concern…
giuffre-maxwell
gov.uscourts.nysd.447706.1351.0
32 pg
…3d at 46. 4 In the extensive discovery conducted in
that action, several hundred documents were produced, prompting
multiple sealing motions to Judge Sweet, which resulted in “nearly one-fifth
of the docket” being filed under seal. Id. 5 Those…
giuffre-maxwell
gov.uscourts.nysd.447706.551.0
17 pg
…the Order as to Prof. Dershowitz does not adjudicate the instant motion.
3.0 Conclusion
Both parties are public figures and the case has been covered by multiple state and national
media outlets. The media has a vested interest in…
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