giuffre-maxwell
gov.uscourts.nysd.447706.1188.0
3 pg
…10007
Re: Giuffre v. Maxwell,
Case No. 15-cv-7433-LAP
Dear Judge Preska,
The Original Parties write in response to the Court’s December 14, 2020, order directing
them to confer about a proposed next set of docket entries…
giuffre-maxwell
gov.uscourts.nysd.447706.1046.0
3 pg
…the March 31, 2020 telephone
conference, to identify the first five motions for the unsealing process. The Original Parties have
met and conferred multiple times to propose five motions pertaining to J. Doe 1 and J. Doe 2, as
identified…
giuffre-maxwell
gov.uscourts.nysd.447706.1144.0
1 pg
…Protocol (dkt. no. 1108), the
original parties to this action may file their own objections to
the unsealing of the materials served on Doe 1 no later than
November 12, 2020, as provided by Paragraph 2(f) of the
Protocol. …
giuffre-maxwell
gov.uscourts.nysd.447706.1213.1
10 pg
…unsealing has not yet expired.
to Improper Objection
344 Already public.
346 Unseal in full. Note: Original parties agree.
346-1 Unseal in full. Note: Original parties agree.
Unseal and redact only names and identifying …
giuffre-maxwell
gov.uscourts.nysd.447706.1227.0
2 pg
…2021, letter to the Court to correct
certain inaccuracies and to address certain criticisms of the Original Parties.
First, Doe criticizes the Original Parties’ compliance with the Court’s unsealing orders and
directives to redact the names of non-parties…
giuffre-maxwell
gov.uscourts.nysd.447706.1300.0
4 pg
…above-captioned matter.
2. On August 26, 2020, the Court ordered the Original Parties to serve Non-Party
Notices on all remaining Non-Parties, ECF No. 1107, and the Original Parties agreed to split
responsibility for mailing the Non-Party…
giuffre-maxwell
gov.uscourts.nysd.447706.364.0
32 pg
…TO INTERVENE
UNDER FEDERAL RULE OF CIVIL PROCEDURE 24(B) ..............................11
A. There Is Significant Overlap Between the Subject Matter
of the Original Action and This Motion ....................................................12
…
giuffre-maxwell
gov.uscourts.nysd.447706.1025.0
17 pg
…Order and Protocol Governing the Excerpts (“Non-
Party Request”);
• Form – Non-Party’s Objection to Unsealing (“Non-Party Objection”).
The original parties have conferred between themselves and with counsel for
Intervenors Brown and Miami Herald and for J. Doe (collectively…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.36_1
35 pg
…of . The
process may take some time but it is the appropriate method for you to obtain any possible records
regarding your recovery. Hope this helps.
Best wishes,
Jason
-----Original Message-----
From:
Sent: Wednesday, August 27, 2014 9:49 AM…
giuffre-maxwell
gov.uscourts.nysd.447706.1116.0
3 pg
…August 26, 2020 Order (Doc. #1107), directing the Original
Parties to serve Non-Party Notices on all remaining Non-Parties, as well as to Does 1 and 2 at
newly obtained addresses, and after conferral with Plaintiff’s counsel, undersigned…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.24
2 pg
…Roberts so not a new individual.
The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue.
The original allegations are not new and have been fully responded to and shown to
be untrue
Each time the story Is re…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.33
3 pg
…ny
., Smart vlOriginal Message------
Unread To: Sara new num
Sent: Feb 2, 2007 6:58 PM
Starred
Subject: Natalie from ny
People
Hey Sarra
Social
…
giuffre-maxwell
gov.uscourts.nysd.447706.908.0
4 pg
…with Plaintiff Virginia Giuffre
at the United States Consulate in Sydney, Australia. During that meeting, Plaintiff informed FBI
Special Agents of the existence of multiple original photographs. See Edwards Declaration, FBI
302 attached hereto as Exhibit A. On March 18…
giuffre-maxwell
gov.uscourts.nysd.447706.1052.0
4 pg
…NY 10007
Re: Giuffre v. Maxwell,
Case No. 15-cv-7433-LAP
Dear Judge Preska,
The Original Parties jointly write to seek clarification of the following parts of the Protocol
for Unsealing Decided Motions, ECF No. 1044:
at a time…
giuffre-maxwell
gov.uscourts.nysd.447706.1045.0
2 pg
…motions under its Order and Protocol (DE 1044). Unfortunately, counsel for the original
parties were unable to reach an agreement as to the sequence of motions. I also write to
submit a joint proposed redacted Decided Motions List.
First, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1115.0
4 pg
…in the above-captioned matter.
2. Pursuant to this Court’s August 26, 2020, order directing the Original Parties to serve
Non-Party Notices on all remaining Non-Parties, ECF No. 1107, the Original Parties
agreed to split responsibility for…
giuffre-maxwell
gov.uscourts.nysd.447706.1120.0_2
1 pg
…Motion to Intervene and for
Confidential Access to Judicial Records and Discovery Documents.
(See dkt. no. 1119.) The USVI was originally ordered to reply to
a separate opposition filed by Defendant Ghislaine Maxwell no later
than September 23, 2020. (Dkt…
giuffre-maxwell
gov.uscourts.nysd.447706.981.0
2 pg
…No.: 1:15-cv-07433-LAP
Dear Judge Preska:
Intervenor Michael Cernovich d/b/a Cernovich Media originally sought to intervene and
unseal the wholly-redacted summary judgment documents filed by Defendant Ghislaine
Maxwell and the subsequent summary judgment documents…
giuffre-maxwell
gov.uscourts.nysd.447706.363.5
6 pg
…CIV-
MARRA/JOHNSON, [ECF No. 291-1] (the “Federal Action”).
2. All photographs and video in the original, native format in which they were taken (not a
paper copy) of you with Alan M. Dershowitz.
3. All photographs and video…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…Non-Parties List: Plaintiff Virginia Giuffre and Defendant Ghislaine Maxwell
(collectively, the “Original Parties”) each have submitted under seal a list of non-parties whose
privacy, reputational or other interests may be implicated by the unsealing of the Sealed Materials…