giuffre-maxwell
gov.uscourts.nysd.447706.1015.0
4 pg
…5, 2019, Letter to the Court Must Be Docketed.
Notice of a filing under seal must be entered on the docket, to afford the public an
opportunity to contest the sealing of that document. See United States v. Haller, 837…
giuffre-maxwell
gov.uscourts.nysd.447706.1119.0_3
4 pg
…ultimately determine what, if any, public access rights attach to presently sealed
filings through a process carefully designed to afford the parties and non-parties alike notice and
an opportunity to be heard. Upon completion of this process, the seal…
giuffre-maxwell
1320-3
6 pg
…give career
14 advice to people and I think that becoming
15 somebody in the healthcare profession, either
16 exercise instructor or nutritionist or
17 professional massage therapist is an
18 excellent job opportunity. Hourly wages are
19 around 7 …
giuffre-maxwell
gov.uscourts.nysd.447706.233.0
9 pg
…2016 e-
mail referenced, however Epstein’s counsel had the opportunity to make that offer in response to the prior phone
conferences and e-mail correspondence that took place in early March. See McCawley Declaration at Exhibit 1.
2
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.3
6 pg
…give career
14 advice to people and I think that becoming
15 somebody in the healthcare profession, either
16 exercise instructor or nutritionist or
17 professional massage therapist is an
18 excellent job opportunity. Hourly wages are
19 around 7 …
giuffre-maxwell
gov.uscourts.nysd.447706.1231.0
3 pg
…to (1) ensure that redacted versions of the
Does’ objections are filed on the public docket and (2) ensure that Intervenors have an opportunity
to respond to the Does’ objections.
The court outlined the following procedure regarding placement of the…
giuffre-maxwell
gov.uscourts.nysd.447706.610.0
3 pg
…assumed to have supported their papers with admissible
evidence”). “If the rationale behind access is to allow the public an opportunity to assess the
correctness of the judge’s decision, documents that the judge should have considered or relied
1…
giuffre-maxwell
gov.uscourts.nysd.447706.751.9
3 pg
…damages," the former
Harvard Law professor said. "I welcome that lawsuit. I welcome any opportunity that would put her under oath and
require her to state under oath these false allegations."
The Associated Press contributed to this report.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.4_2
6 pg
…14 advice to people and I think that becoming
15 somebody in the healthcare profession, ei t her
16 exercise instructor or nutritionist or
17 professional massage therapist is an
18 excellent job opportunity . Hourly wages are
19 around 7…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.18
11 pg
…less burdensome, or less extensive, (2) the party seeking discovery has had
ample opportunity to obtain the information by discovery in the action, and (3) the burden or
expense of the proposed discovery outweighs its likely benefit, considering the needs…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.36
10 pg
…Mr. Epstein submitted to deposition under oath and recorded on video. At that
deposition, the parties had an unlimited opportunity to examine him at length, asking approximately
600 separate questions, to all of which Mr. Epstein asserted his Fifth Amendment…
giuffre-maxwell
gov.uscourts.nysd.447706.1318.0
3 pg
…to
the Does designated following its particularized review of the
documents noted: as set forth herein. The Court stays its order
for fourteen days to permit any impacted Doe the opportunity to
appeal, after which counsel are asked to confer…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.2
73 pg
…7 Page 9
1 G. Maxwell - Confidential 1 G. Maxwell - Confidential
2 2 form and foundation, and I have an
3 3 opportunity to do that.
4 …
giuffre-maxwell
gov.uscourts.nysd.447706.997.0
5 pg
…2006) (explaining
that “the rationale behind access is to allow the public an opportunity to assess the correctness of
the judge’s decision” (internal quotation marks omitted)).
3
Case 1:15-cv-07433-LAP Document 997 Filed 10/09…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.16
22 pg
…Defendant Epstein gave Plaintiffno
option, opportunity or choice not to participate in the prescribed sexual acts.
t2
Case 1:17-cv-00616 Document 1 Filed O\l26lt7 Page L3 of 21
4. Defendant Ma:rwell frequently controlled the assignment…
giuffre-maxwell
gov.uscourts.nysd.447706.1317.0
3 pg
…to
the Does designated following its particularized review of the
documents noted: as set forth herein. The Court stays its order
for fourteen days to permit any impacted Doe the opportunity to
appeal, after which counsel are asked to confer…
giuffre-maxwell
gov.uscourts.nysd.447706.189.0
11 pg
…less burdensome, or less extensive, (2) the party seeking discovery has had
ample opportunity to obtain the information by discovery in the action, and (3) the burden or
expense of the proposed discovery outweighs its likely benefit, considering the needs…
giuffre-maxwell
gov.uscourts.nysd.447706.753.1
7 pg
…addition, with regard to the financial information,
19 your Honor has directed the defense to produce all of the
20 financial information but just shortly before trial. So we
21 haven't had an opportunity to look at, for example…
giuffre-maxwell
gov.uscourts.nysd.447706.749.0
9 pg
…v. Grief Brothers Corp., 218 F.R.D. 59, 61–62 (W.D.N.Y. 2003).................................... 25
Equal Employment Opportunity Comm’n v. Reed Pierce’s Sportsman’s Grille, LLC, No. 3:10-
CV-541-WHB-LRA, 2013 WL 12123370…
giuffre-maxwell
gov.uscourts.nysd.447706.1024.0
7 pg
…at *8. And if the parties settle before a judge has the
opportunity to rule on a motion, all the more reason for the public to gain access to the undecided
motions so that they may understand how the motions…