giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…Ms. Giuffre’s Confidential Communications With Her Attorneys Were Never “At
Issue” in the Florida Dershowitz Litigation....................................................................19
D. Defendant Has Not Met the Other Requirements for Showing Waiver of Attorney-
Cli…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.14_2
40 pg
…Attorneys Were Never “At
Issue” in the Florida Dershowitz Litigation. ................................................................... 19
D. Defendant Has Not Met the Other Requirements for Showing Waiver of Attorney-
Client Privilege...........................…
giuffre-maxwell
1320-18
40 pg
…Ms. Giuffre’s Confidential Communications With Her Attorneys Were Never “At
Issue” in the Florida Dershowitz Litigation....................................................................19
D. Defendant Has Not Met the Other Requirements for Showing Waiver of Attorney-
Cli…
giuffre-maxwell
gov.uscourts.nysd.447706.185.4
10 pg
…06/01/16 Page
3 of"
10
On December 30, 2014, two other unnamed victims, Jane Doe 3 and Jane Doe 4, moved
to join as petitioners in this action pursuant…
giuffre-maxwell
gov.uscourts.nysd.447706.363.4
11 pg
…11
Docket 04/07/2015 Page 2 of 10
On December 30, 2014, two other unnamed victims, Jane Doe 3 and Jane Doe 4, moved
to join as petitioners in this action pursuant to Federal Rule of Civil Procedure 21…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.5
11 pg
…of Page
04/07/2015 11 2 of 10
On December 30, 2014, two other unnamed victims, Jane Doe 3 and Jane Doe 4, moved
to join as petitioners in this action pursuant to Federal Rule of Civil Procedure 21…
giuffre-maxwell
gov.uscourts.nysd.447706.1353.0
6 pg
…during the grand jury investigation of Jeffrey
Epstein, Ghislaine Maxwell, and others, certain materials of which have since been filed under
seal on this Court’s docket.
The late Honorable Robert W. Sweet issued a protective order for the Materials…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.0
18 pg
…2015
Page 3 of Page
11 2 of 10
On December 30, 2014, two other unnamed victims, Jane Doe 3 and Jane Doe 4, moved
to join as petitioners in this action pursuant to Federal Rule …
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…to join in the CVRA case. These petitioners
included in their filings not only descriptions of sexual abuse by
Epstein, but also new allegations of sexual abuse by several other
prominent individuals, “including numerous prominent American
politicians, powerful business executives…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…to join in the CVRA case. These petitioners
included in their filings not only descriptions of sexual abuse by
Epstein, but also new allegations of sexual abuse by several other
prominent individuals, “including numerous prominent American
politicians, powerful business executives…
giuffre-maxwell
gov.uscourts.nysd.447706.978.0
27 pg
…to join in the CVRA case. These petitioners
included in their filings not only descriptions of sexual abuse by
Epstein, but also new allegations of sexual abuse by several other
prominent individuals, “including numerous prominent American
politicians, powerful business executives…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.1
13 pg
…Prince Andrew, and others. Further efforts from the Government to avoid
producing any discovery followed (see generally DE 225-1 at 4-5),2 ultimately leading to a
further Court ruling in June 2013 that the Government should produce documents…
giuffre-maxwell
gov.uscourts.nysd.447706.941.0
6 pg
…in
support of and against summary judgment. Ultimately, the rationale of the denial of unsealing was
boiled down to the following countervailing factors:
1
Available at: (last accessed Apr. 19…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.45
13 pg
…Dershowitz, , and others. Further efforts from the Government to avoid
producing any discovery followed (see generally DE 225-1 at 4-5),2 ultimately leading to a
further Court ruling in June 2013 that the Government should produce documents. DE…
giuffre-maxwell
gov.uscourts.nysd.447706.977.0
27 pg
…to join in the CVRA case. These petitioners
included in their filings not only descriptions of sexual abuse by
Epstein, but also new allegations of sexual abuse by several other
prominent individuals, “including numerous prominent American
politicians, powerful business executives…
giuffre-maxwell
gov.uscourts.nysd.447706.970.0
2 pg
…to
confer and appear for a conference tomorrow to discuss how to proceed. We
have begun conferrals with the other parties.
This firm represents the defendant Ghislaine Maxwell. As the appellee in the
consolidated appeals of Judge Sweet’s orders…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…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
(each, a “Non-Party,” and collectively, the “Non…
giuffre-maxwell
gov.uscourts.nysd.447706.1034.0
16 pg
…the names of reporters,
1
Case 1:15-cv-07433-LAP Document 1034 Filed 03/19/20 Page 2 of 16
Plaintiff’s medical providers, and law enforcement personnel
but retains all other potentially relevant non-parties. (See
dkt…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…would
be entitled to relief, pending development of a fuller evidentiary record. Id.
Two other victims, who are in many respects similarly situated to the current victims,
now wish to join this action. The new victims joining at this stage…
giuffre-maxwell
gov.uscourts.nysd.447706.1278.0
4 pg
…1
In connection with this letter motion, the undersigned counsel has attempted to
communicate with the other interested parties to the above referenced case but is still
awaiting a response from the parties. Should any party object to the relief…
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