giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…safety of witnesses, national security, and trade secrets).
I. Other interests. See Hardy, 697 Fed. App’x at 725 (“Courts have found that interests
such as protection of ongoing investigations, safety of witnesses, national security, and
trade secrets may be…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…v.
Aref, 533 F.3d 72 (2d Cir. 2008) (finding that where classified
information presented at trial, if disclosed, would jeopardize
national security weighed against public access); Lugosch v.
Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…x at 725 (2d Cir. 2017) (noting that courts
have found that the following can defeat presumption of access: protection of ongoing
investigations, safety of witnesses, national security, and trade secrets).
Ms. Maxwell is aware, based on publicly reported statements…
giuffre-maxwell
gov.uscourts.nysd.447706.936.0
21 pg
…partners engaged in kick-back scheme was properly denied where complaint was of "legitimate
interest to the public" and where disclosure would not reveal details of an ongoing investigation,
pose a risk to witnesses, endanger national security, reveal trade secrets…
giuffre-maxwell
gov.uscourts.nysd.447706.1237.0
20 pg
…contact lists, birth dates, and social security
numbers”; (2) “the names of alleged minor victims of sexual abuse”; and (3) “deposition responses
concerning intimate matters where the questions were likely only permitted—and the responses
only compelled—because of a…
giuffre-maxwell
gov.uscourts.nysd.447706.961.0
9 pg
…such return at the conclusion of the
case, including all appeals.” Standard Inv. Chartered, Inc. v. National Ass'n of Securities
Dealers, Inc., 2008 WL 199537, at *14 (S.D.N.Y. January 22, 2008) (holding that the relevant
party…
giuffre-maxwell
gov.uscourts.nysd.447706.18.0
5 pg
…as here, a pending motion to
dismiss has “substantial arguments for dismissal of many, if not all, of the claims asserted.”
Spinelli v. National Football League, No. 13-cv-7398 (RWS), 2015 WL 7302266, at *2
(S.D.N.Y…
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
… That's in
16 paragraph 30, 36 and 37, international media, national media
17 and the New York Daily Post, who interviewed Ms. Maxwell on a
18 New York street. So that is alleged in detail in our
19 complaint…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…Conclusion
Maxwell, individually and as a proxy for Epstein, is a public figure and the case has been
covered by multiple state and national media outlets. The media has a vested interest in these and
all court proceedings, and the…
giuffre-maxwell
gov.uscourts.nysd.447706.89.0
10 pg
…board-certified civil trial attorney. He was been selected as
one of the National Trial Lawyer Association’s “Top 40 Under 40” and the National Academy of
Personal Injury Attorney’s Top 10 Under 40. His previous experience will be…
giuffre-maxwell
gov.uscourts.nysd.447706.406.0
31 pg
…Giuffre, as he has already
appeared on national news calling her a “prostitute” and a “bad mother.”1 This is not the typical
intervention case where a non-party seeks documents it lacks access to, or where a news
organization…
giuffre-maxwell
gov.uscourts.nysd.447706.23.0
32 pg
…No. 03CV2947(NG)RML, 2006 WL 2053717 (E.D.N.Y. July 21, 2006) ................................19
Edwards v. National Audubon Society, Inc.,
556 F.2d 113 (2d Cir. 1977) ......................................................................................................10
Fowler v. New York Herald Co.,
184 A.D. 608, 172…
giuffre-maxwell
gov.uscourts.nysd.447706.551.0
17 pg
…ECF No. 348.
1
His Periscope coverage of the Republican National Convention and Democrat National
Convention was featured on Periscope’s main page and served as one of the only real-time sources
of information from those conventions. See Cernovich…
giuffre-maxwell
gov.uscourts.nysd.447706.941.0
6 pg
…be the best of
disinfectants; electric light the most efficient policeman.” L. Brandeis, Other People’s Money and
How the Bankers Use It 62 (National Home Library Foundation ed. 1933), as quoted in Igneri v.
Moore, 898 F.2d 870…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…were published over the course of nearly ten years by
numerous publications, including The Mail on Sunday, the National Enquirer, and Radar Online,
and were written by Ms. Churcher either as an employee of the publication or as freelance
reporter…
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