giuffre-maxwell
gov.uscourts.nysd.447706.1320.8
12 pg
…McCawley Decl. at Exhibit 4, Affidavit of
Douglas G. Mercer, Chief Investigator Alpha Group.
Means such as those described above have been approved by this Court in other cases.
For example, in Medical Diagnostic Imaging, PLLC v. Carecore National, LLC…
giuffre-maxwell
1320-8
12 pg
…McCawley Decl. at Exhibit 4, Affidavit of
Douglas G. Mercer, Chief Investigator Alpha Group.
Means such as those described above have been approved by this Court in other cases.
For example, in Medical Diagnostic Imaging, PLLC v. Carecore National, LLC…
giuffre-maxwell
gov.uscourts.nysd.447706.160.0
12 pg
…McCawley Decl. at Exhibit 4, Affidavit of
Douglas G. Mercer, Chief Investigator Alpha Group.
Means such as those described above have been approved by this Court in other cases.
For example, in Medical Diagnostic Imaging, PLLC v. Carecore National, LLC…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…Ms. Maxwell rightfully remains skeptical of
Plaintiff’s ability to abide by the terms of this Court’s Protective Order when it comes to
confidential financial information.
In other cases involving higher profile individuals and matters, the courts have been…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…last argument that discovery of financial information should be
“limited to a sworn affidavit of net worth.” DE 370 at 13. Whatever may have been the
circumstance warranting limitations in other cases, the circumstances here make that approach
highly inappropriate…
giuffre-maxwell
gov.uscourts.nysd.447706.23.0
32 pg
…that Ms. Giuffre’s
accusations are defamatory - something she has not done, and never can, because the allegations
of sexual abuse are true.
Defendant’s other cases are also readily distinguished. For example, she cites Kane v.
Orange Cty. Publications…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.4_1
29 pg
…Zach, Brockman,
Legal Assistants and Other Professionals.
Plaintiff is withholding “Approx. 1.3 kilobytes [of documents] overlapping with other
cases” based on the categorically logged entries in Paragraph 1.
According to her most recent interrogatory response, Plaintiff has been represented…
giuffre-maxwell
gov.uscourts.nysd.447706.1062.0
7 pg
…and thus counter to law. Courts in this Circuit strongly disfavor attempts by collateral
litigants to modify protective orders entered in other cases. The Second Circuit has held that
where there has been reasonable reliance by a party or non…
giuffre-maxwell
gov.uscourts.nysd.447706.164.0
29 pg
…Zach, Brockman,
Legal Assistants and Other Professionals.
Plaintiff is withholding “Approx. 1.3 kilobytes [of documents] overlapping with other
cases” based on the categorically logged entries in Paragraph 1.
According to her most recent interrogatory response, Plaintiff has been represented…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.33
24 pg
…none of the necessary information or an
actual computation of damages, relying on other people’s alleged earning potential and average
damage awards in other cases with completely different claim types. See Motion to Compel
Rule 26(a) Disclosure at…
giuffre-maxwell
gov.uscourts.nysd.447706.949.0
31 pg
…not to be
6 judicially resolved. But clearly dispositive motions have a
7 presumption of access and are judicial documents.
8 There's Logosch and a bunch of other cases we cited,
9 including the Second Circuit's decision Joy. …
giuffre-maxwell
gov.uscourts.nysd.447706.1198.1_2
24 pg
…none of the necessary information or an
actual computation of damages, relying on other people’s alleged earning potential and average
damage awards in other cases with completely different claim types. See Motion to Compel
Rule 26(a) Disclosure at…
giuffre-maxwell
1320-33
24 pg
…none of the necessary information or an
actual computation of damages, relying on other people’s alleged earning potential and average
damage awards in other cases with completely different claim types. See Motion to Compel
Rule 26(a) Disclosure at…
giuffre-maxwell
gov.uscourts.nysd.447706.49.0
12 pg
…media about Ms. Maxwell and others. Plaintiff, in this
matter, has repeatedly attached transcripts from unrelated matters, news articles about public
figures, material obtained from government investigations, and discovery obtained in other cases
to her hyperbolic pleadings. These attachments appear…
giuffre-maxwell
gov.uscourts.nysd.447706.231.0
23 pg
…none of the necessary information or an
actual computation of damages, relying on other people’s alleged earning potential and average
damage awards in other cases with completely different claim types. See Motion to Compel
Rule 26(a) Disclosure at…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.21
15 pg
…The Court is well aware of many other
civil cases where the parties have taken far more than ten depositions by mutual agreement.
Defendant’s refusal to agree to a few more depositions here is simply an effort to keep…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.24
16 pg
…The Court is well aware of many other
civil cases where the parties have taken far more than ten depositions by mutual agreement.
Defendant’s refusal to agree to a few more depositions here is simply an effort to keep…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.17_1
16 pg
…The Comt is well aware of many other
civil cases where the patties have taken fai· more than ten depositions by mutual agreement.
Defendant's refusal to agree to a few more depositions here is simply an effo1t to keep…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.27
15 pg
…The Court is well aware of many other
civil cases where the parties have taken far more than ten depositions by mutual agreement.
Defendant’s refusal to agree to a few more depositions here is simply an effort to keep…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.18_2
15 pg
…The Comt is well aware of many other
civil cases where the patties have taken fai· more than ten depositions by mutual agreement.
Defendant's refusal to agree to a few more depositions here is simply an effo1t to keep…
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