giuffre-maxwell
gov.uscourts.nysd.447706.1226.0
4 pg
…for Unsealing Decided Motions. See DE 1224.
We write to express our views regarding the parties’ respective submissions, as well as that
offered by the Miami Herald. See DE 1225.
As directed by the Second Circuit, this Court has made…
giuffre-maxwell
gov.uscourts.nysd.447706.730.0
14 pg
…BACKGROUND .............................................................................................. 1
III. DISCUSSION ...................................................................................................................... 2
A. Ms. Giuffre’s FBI 302 is Offered to Prove That She Reported Her Alleg…
giuffre-maxwell
gov.uscourts.nysd.447706.1248.0
6 pg
…Supp. 2d at 621–22. It does not appear that the Does have offered the
requisite “specific facts,” nor that closure is “essential to preserve higher values.” See Delta Air
Lines, 2020 WL 2614704, at *4.
Intervenors address the Does…
giuffre-maxwell
gov.uscourts.nysd.447706.1351.0
32 pg
…2) holding that the transcript of Giuffre’s
deposition in a separate action, offered by a third-party in support of a
motion to intervene in this case, was entitled to no more than a “barely
cognizable” presumption of public…
giuffre-maxwell
gov.uscourts.nysd.447706.1155.0_2
13 pg
…and submit this response based on the known
portions of the documents as well as the parties’ public representations as to their contents.
Intervenors incorporate by reference their arguments offered in response to the alleged
“Countervailing Interests” identified by Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1204.0
3 pg
…Raddatz, 447 U.S. 667, 677 (1980) (due process guarantees an
accused the right to challenge the admissibility of evidence offered against her). If the
government’s conduct was unlawful and unconstitutional, as Ms. Maxwell contends it was,
Judge Nathan…
giuffre-maxwell
gov.uscourts.nysd.447706.1349.0
31 pg
…2) holding that the transcript of Giuffre’s
deposition in a separate action, offered by a third-party in support of a
motion to intervene in this case, was entitled to no more than a “barely
cognizable” presumption of public…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…offered to have sex with
him in exchange for not telling her parents she had failed to go to school that day.
Both Plaintiff and her 17-year old boyfriend verified they had had sexual
intercourse in the days before…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.0
35 pg
…the proposition that
a trial court can violate a defendant’s due process rights when it fails to take precautions against
the dissemination to jurors of evidence made available to the media that was never offered at trial.
Maxwell Br…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…presumably, to the protective order. We had
17 previously offered defense counsel to sign the acknowledgment
18 of the protective order, which does provide for disclosure to
19 witnesses and witnesses' counsel. They didn't take us up on it…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…case, the Supreme
Court held the trial court violated defendant’s due process rights when it failed to take
precautions to prevent dissemination of “evidence [made] available to the news media which
was never offered in the trial.” Id. at…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.31
13 pg
…public. At
the very least, the Court should conduct an in camera review of any joint defense agreements
that exist to determine their relevance to both the defamation claim and the multiple affirmative
defenses offered by Defendant. See Steuben Foods…
giuffre-maxwell
gov.uscourts.nysd.447706.63.0
22 pg
… id. at 17:5 (“I
produced 3,000 pages”). She also offered to produce any documents that she intended to “use”
at the March 25 deposition.
Counsel engaged in a conferral on March 21, 2016, regarding the deficiencies in
Plaintiff…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…273 F.3d at 233. The references to the various
attached exhibits were gratuitous and served no legitimate purpose related to the discovery
dispute. During the course of this litigation Plaintiff offered, on more than one occasion, various
iterations and…
giuffre-maxwell
gov.uscourts.nysd.447706.849.0
94 pg
… they relate to
24 credibility issues of the plaintiff in this case. Replete
25 through the opinion, original opinion that he offered, are a
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document…
giuffre-maxwell
gov.uscourts.nysd.447706.847.0
94 pg
… they relate to
24 credibility issues of the plaintiff in this case. Replete
25 through the opinion, original opinion that he offered, are a
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…have found that the privacy interests of third persons
warranted the sealing of a record or redactions thereto notwithstanding a presumption of access. In addition to the
cases cited above, the following are offered as examples: Am. Friends Ser. Comm…
giuffre-maxwell
gov.uscourts.nysd.447706.185.8
24 pg
…filed a claim, based upon a matter ordinarily
privileged, the proof of which will necessarily require that the privileged matter be offered in
evidence, [the Florida Supreme Court has held] that he has waived his right to insist, in pretrial…
giuffre-maxwell
gov.uscourts.nysd.447706.892.0
11 pg
…is currently
scheduled for trial in mid-May and a release of contested
confidential discovery materials could conceivably taint the
jury pool.
Further, there was "no viable basis to deny the
motion" offered in In re Pineapple, 2015 WL 5439090…
giuffre-maxwell
gov.uscourts.nysd.447706.994.0
14 pg
…been identified that would warrant sealing any of these documents.
Category 6: Filings Related to Third-Party Intervenors
Court filings to intervene and exhibits offered in support of same are judicial documents to
which a substantial presumption of access attaches…