…defense team, and the ultimate decision by the U.S. Attorney's Office to sign a non-prosecution agreement that was negotiated in secret and sealed in return for a guilty plea to a lesser state crime. The deal, which…
… Case 1:15-cv-07433-LAP Document 1199-1 Filed 01/27/21 Page 11 of 13 See GM_00577. Non-prosecution of a rape does not mean the rape didn’t happen, and that in the United States…
… I am here to get this BS non- prosecution agreement thrown out and speaking w Judge Paul Cassal he suggested trying to get ahold of any photos and/or video recordings released by the FBI to assist our case further…
… Even though the U.S. Attorney’s Office had previously entered into a Non- Prosecution Agreement with Epstein and his potential co-conspirators, the Office would have been entitled to investigate the involvement of any other persons in sex trafficking…
…and non-victim witnesses for the prosecution to testify under pseudonyms “because the disclosure of their identities would necessarily reveal the identities of the alleged victims.” Id. at *1. Accordingly, even bare disclosure of names or information concerning potential non…
…of deposition testimony and lawyer vitriol into 1 The Countervailing Interests include: 1. Reasonable reliance on the Protective Order by a party or non-party (“CI-1”). 2. Prevention of the abuse of court records and files (“CI-2”).1 …
…2013), are inapposite. In Silver, the court noted that the non-parties had “not otherwise been connected to or named in Defendant’s criminal prosecution.” 2016 WL 1572993, at *6. Here, Doe 144 has been publicly connected to Plaintiff’s…
…the midst of her criminal prosecution and trial fundamentally violates her due process rights.” ECF No. 1208 at 3. Should she choose to make this same argument (again), she may do so in her briefing concerning Non-Party Objections. …
…Plaintiff’s Position: Mindful of the Court’s directive that “the parties’ proposals should accord with the Unsealing Protocol previously issued by this Court, including with respect to identification and notification of any affected non-parties,” Dkt. 1352 at 1…
…2020 ruling concluding that the transcripts of Ms. Maxwell’s April 2016 deposition and Doe 1’s deposition should be unsealed in their entirety (with the exception of non-party names). We recognize that a reconsideration motion is an extraordinary…
…in their pleadings and cannot satisfy it. ARGUMENT I. THE GOVERNMENT CANNOT INTERVENE OR MODIFY THE PROTECTIVE ORDER FOR ACCESS TO NON-JUDICIAL DISCOVERY MATERIALS The Government buries the lead in its Motion. It first seeks four sets of documents…
…to claim that, for this next set of motions, the Court should keep sealed “all quotes from Ms. Maxwell and Non-Party deposition testimony, Non-Party identifying information, and argument of counsel.” ECF No. 1150-1 at 1. Maxwell still…
…practice concerning these issues, and throughout all of the meet and confers, Defendant’s counsel has never presented a case supporting the far-fetched position that non-privileged documents in the possession of the 2 Furthermore, Ms. Giuffre’s correspondence…
…statute. 4 remedies.” In any event, none of the parties has produced any records from any juvenile prosecution. Nor does section 794.026 have any relevance to this action. That statute creates a cause of action by a sexual crime…
…similar fashion. 1 Case 1:15-cv-07433-LAP Document 993 Filed 10/02/19 Page 5 of 23 The only category that Maxwell claims “contains exclusively non-judicial documents” is Category 4 (Trial Deposition Designations and Counter-Designation)…
…21 the 302 motion; and there are three that seem to me to go 22 together -- the references to the Florida action, the CVRA 23 action; the Epstein plea agreement and nonprosecution, and 24 registration; and the victim notification letter. …
…21 the 302 motion; and there are three that seem to me to go 22 together -- the references to the Florida action, the CVRA 23 action; the Epstein plea agreement and nonprosecution, and 24 registration; and the victim notification letter. …
Case 1:15-cv-07433-LAP Document 1237-1 Filed 01/12/22 Page 1 of 6 Exhibit A Docket Entry Non-Party Plaintiff’s Position Does 122-7 J. Doe 54, J. Doe Unseal and redact only names and…
…YORK Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ NON-PARTY SARAH RANSOME’s RESPONSES AND OBJECTIONS TO DEFENDANT’S SUBPOENA REQUESTS Sarah Ransome, a non…
…6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Virginia L. Giuffre, Plaintiff, v. Case No.: 15-cv-07433-LAP Ghislaine Maxwell, Defendant. INTERVENORS’ JULIE BROWN AND MIAMI HERALD MEDIA CO.’S RESPONSE TO NON-PARTIES 12, 28, 97…