giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…Preska
November 16, 2019
Page 3
numbers,” and “the names of alleged minor victims of sexual abuse from deposition
testimony and police reports, as well as deposition responses concerning intimate
matters where the questions were likely only permitted—and the…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…brief
11 on this matter.
12 We wrote a letter to opposing counsel citing some
13 governing provisions of Microsoft's email policy that indicates
14 that due to inactivity they delete accounts after a certain
15 amount of time…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…07433-LAP Document 1057 Filed 06/10/20 Page 4 of 17
excerpts from Ms. Maxwell’s deposition. Exhibit 3 contains pages from the Palm Beach Police
Report. DE 149 is Ms. Maxwell’s response to DE 143.
Page 2…
giuffre-maxwell
gov.uscourts.nysd.447706.185.8
24 pg
…nature of this suit, which puts the legal advice defendants received directly in issue, the policy
behind the privilege is outweighed by the necessity of disclosure and the privilege is
inapplicable.”). Plaintiffs’ objections should be overruled, and they should be…
giuffre-maxwell
gov.uscourts.nysd.447706.1215.0
13 pg
…at 1; contra DE 406 at 19 (“And again, the
Court should not lose sight of the policy rationale behind the First Amendment right of access:
the accountability of the courts to the public.”). Now that it is Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…Background ........................................................................................................................ 2
I. THE DOCUMENTS AT ISSUE ARE NOT CONFIDENTIAL............................................. 4
A. Plaintiff’s Police Records Are Publicly Available from Law Enforcement Agencies in
…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.1_1
13 pg
…the
Court’s Protective Order, Ms. Giuffre marked as confidential highly sensitive documents and
Defendant is now challenging that designation. Defendant objects to maintaining as confidential
police reports involving Ms. Giuffre, including two police reports describing Ms. Giuffre as a
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.31
13 pg
…This Court should Order Production of Documents Responsive to Requests
Nos. 1-3
Defendant characterizes the police reports (and information therein) concerning Ms.
Giuffre as a minor as both “highly relevant” (Br. at 4) and “irrelevant” to this action (Br…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.8
29 pg
…or relied upon” in a phone
call with Plaintiff’s counsel. ...................................................................................... 1
B. RFP Nos. 2-3: Documents concerning “how” the defense obtained “police
report(s).” ...............................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.6_1
14 pg
…Background ........................................................................................................................ 2
I. THE DOCUMENTS AT ISSUE ARE NOT CONFIDENTIAL............................................. 4
A. Plaintiff’s Police Records Are Publicly Available from Law Enforcement Agencies in
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.26
5 pg
…of 5
Page 84
1 G Maxwell - Confidential
2 30 girls --
3 A. I did not count the number of girls
4 and I did read the police report. I can only
5 testify to what I read.
6 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…six months after representing to this Court that this case involves “highly
personal and sensitive information” warranting a broad protective order, Defendant now wants to
publicize police reports concerning Ms. Giuffre - most of them from when she was a child…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.4_1
4 pg
…likely because there is none."). I
disagree.
Your latest produc6on includes a police report detailing the rape of a 14 year old child,
my client. Other materials you produced include police records concerning my client while she
was a minor…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…six months after representing to this Court that this case involves “highly
personal and sensitive information” warranting a broad protective order, Defendant now wants to
publicize police reports concerning Ms. Giuffre - most of them from when she was a child…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.36_1
35 pg
…about the dates which you have already said that's fine. I have turned the Wilton
Manors police dept upside down looking through records and come up w nada. What was your
acquaintance's name that took my statement about…
giuffre-maxwell
gov.uscourts.nysd.447706.1196.0
32 pg
… By its terms, this rule applies to
21 "lawyers or law firms, "government agents and police officers,"
22 "in connection with pending or imminent criminal litigation
23 with which they are associated. Id. It is not clear to the
24…
giuffre-maxwell
gov.uscourts.nysd.447706.1237.0
20 pg
…g
Tr. 7:5-8 (“It’s not the job of the Court to police press coverage and alert the public when reporting
on unsealed materials as yesterday’s news when the unsealed material is already public.”).8
Further, Does…
giuffre-maxwell
gov.uscourts.nysd.447706.1220.0
17 pg
… It's not the
6 job of the Court to police press coverage and alert the public
7 when reporting on unsealed materials as yesterday's news when
8 the unsealed material is already public.
9 As for the names…
giuffre-maxwell
gov.uscourts.nysd.447706.1213.0
18 pg
…from the articles themselves. Id. at 2–3.
2
Case 1:15-cv-07433-LAP Document 1213 Filed 02/12/21 Page 7 of 18
guards against the miscarriage of justice by subjecting the police, prosecutors, and judicial
processes…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…the court should have made some
effort to control the release of leads, information, and gossip to the press by police officers,
witnesses, and the counsel for both sides. Much of the information thus disclosed was inaccurate,
leading to groundless…