giuffre-maxwell
gov.uscourts.nysd.447706.2.0
2 pg
…of 2
JS 44C/S DNY CIVIL COVER SHEET
REV 4/2014
The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of
pleadings or other papers as reqwred by law…
giuffre-maxwell
gov.uscourts.nysd.447706.1249.0
1 pg
…93, and 151. The parties to this action and other
interested parties are invited to appear telephonically for the
Court’s rulings as to these objections on Tuesday April 19,
2022, at 10:30 a.m., using the following information…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.1267.0
2 pg
…of Holland & Knight, and all other papers and proceedings herein, undersigned counsel
moves this Court for an Order pursuant to Local Rule 1.4 granting this Motion to Withdraw
Sanford Bohrer as Counsel for Intervenors Julie Brown and Miami Herald…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.1271.0
1 pg
…171, and 183. The parties to this action and other
interested parties are invited to appear telephonically for the
Court’s rulings as to these objections on Friday November 18,
2022, at 11 a.m., using the following information: dial…
giuffre-maxwell
gov.uscourts.nysd.447706.935.0
1 pg
…an order unsealing all of the documents in the
above-captioned action that have been filed under seal or redacted, and granting such other and
further relief as this Court deems just and proper.
Dated: April 6, 2018
New York…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.16
22 pg
…Sarah Kellen,
Lesley Groff, and Natalya Malyshw, alleges upon personal knowledge with
respect to her own acts and status and upon information and belief as to all other
matters, as follows:
1. This cause of action arises under federal statutes…
giuffre-maxwell
1320-37
48 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.140.2
3 pg
…Privilege, In General
III. Particular Privileges
D. Other Particular Privileges
References
§ 23:38. “Public interest” privilege
The “public intere…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.3
19 pg
…about 1997, MAXWELL assisted, facilitated, and
contributed to Jeffrey Epstein's abuse of minor girls by, among
other things, helping Epstein to recruit, groom, and ultimately
abuse victims known to MAXWELL and Epstein to be under the age
of 18. …
giuffre-maxwell
gov.uscourts.nysd.447706.216.8
4 pg
…뒫davit from former “sex slave” Virginia Roberts, in which she
instructs a top legal team to seek criminal charges against Prince Andrew, Alan Dershowitz, and other high-powered pals
of billionaire pedophile Jeffrey Epstein — including, potentially, Bill Clinton!
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.32
4 pg
…visits
was to have me have sexual relations with Jeffrey, Nadia Macinkova, and various
other girls and guests he brought to the island.
3. During one ofmy visits to the island I met Ghislaine Maxwell. Watching her
interact with the…
giuffre-maxwell
gov.uscourts.nysd.447706.1098.0
2 pg
…cv-3377. The Court invited any Doe who
wishes to be heard on potential disclosure to Mr. Dershowitz to submit his or her objections or
other comments directly to the Court via email, for the Court’s in camera review. …
giuffre-maxwell
gov.uscourts.nysd.447706.1137.2_2
4 pg
…tness not to
20 answer.
21 MS . McCAWLEY: This case involves
22 sexual trafficking , sexual abuse,
23 questions about her having interactions
24 with other females is relevant to this
25 case. She needs to answer these
MAGNA9 LEGAL SERVICES
giuffre-maxwell
gov.uscourts.nysd.447706.1300.0
4 pg
…Party pseudonyms of the Non-Parties to whom
Plaintiff sent the Non-Party Notices. Plaintiff has confirmed that this error has not had any other
impact on the unsealing process thus far.
6. Pursuant to this Court’s August 26…
giuffre-maxwell
gov.uscourts.nysd.447706.1318.0
3 pg
…2023
Page-2-
does not extend to other purported victims living in countries
without the same risks of physical harm.
The Parties therefore respectfully request the Court’s permission
to maintain th…
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