giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…that he never saw any naked photos at Epstein’s Palm Beach mansion, the
recently released video taken by the Palm Beach Police department during its investigation, reveals naked photos in
a number of the common areas of Epstein’s…
giuffre-maxwell
gov.uscourts.nysd.447706.503.0
21 pg
…"New York public
policy as embodied in the Constitution and our current statutory
scheme provides a mantle of protection for those who gather and
report the news-and their confidential sources-that has been
recognized as the strongest in the…
giuffre-maxwell
gov.uscourts.nysd.447706.46.0
22 pg
…law of the country that has
the predominant or the most direct and compelling interest in whether [the] communications
should remain confidential, unless that foreign law is contrary to the public policy of this forum.”
Anwar v. Fairfield Greenwich Ltd.…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…whether Income was received by You or anyone else
concerning such event, whether a police report was ever filed concerning such event and the
outcome of any such case, as well as the address and location of any such event…
giuffre-maxwell
gov.uscourts.nysd.447706.179.0
22 pg
…P. 26(b)(4)(D). 4 There are four commonly articulated policy
3
Additionally, to the extent these non-testifying experts assist in the rendition of legal services,
such as rendering opinions related to Defendant’s electronic discovery, those communications…
giuffre-maxwell
gov.uscourts.nysd.447706.135.0
37 pg
…8~ . 3,7.3, ,..448 ' ~ ~: E ;2 dJ 1_2:1 ., i. ·
(1983). The policy purposes 6f privilege in both jurisdictions
also mi..r ~fn
giuffre-maxwell
gov.uscourts.nysd.447706.193.0
14 pg
…allegedly defamatory statements at issue. New York therefore has the
predominate interest in whether these communications remain confidential. The similarity
between New York and British attorney-client privilege demonstrates that no public policy
conflict exists. Consequently, New York law applies…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.22
31 pg
…that he never saw any naked photos at Epstein’s Palm Beach mansion, the
recently released video taken by the Palm Beach Police department during its investigation, reveals naked photos in
a number of the common areas of Epstein’s…
giuffre-maxwell
gov.uscourts.nysd.447706.57.3
39 pg
…1027.
D
Highgrade Traders Ltd, Re [1984] BCLC 151.
House of Spring Gardens Ltd v Waite [1985] FSR 173.
Jones v Monte Video Gas Co (1880) 5 QBD 556.
L (A Minor) (Police Investigation: Privilege), Re [1997] AC 16.
Lask…
giuffre-maxwell
gov.uscourts.nysd.447706.56.0
14 pg
…the law of the country that has the ‘predominant’ or ‘the most
direct and compelling interest’ in whether those communications should remain confidential,
unless that foreign law is contrary to the public policy of this forum.” 208 F.R.D…
giuffre-maxwell
gov.uscourts.nysd.447706.140.3
4 pg
…a doctor by alleged minor victims of sexual abuse, to bar
disclosure of documents related to police officers’ questioning of nonparty victims in connection with a criminal
investigation of the doctor, inasmuch as disclosure could imperil future investigations and have…
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.447706.218.0
25 pg
…Apr. 22, 2014). Although the “the federal and state policies” on the reporter’s
privilege are “congruent,” id. *4, as discussed further herein, the standards for overcoming the privilege are higher
when the state Shield Law applies.
2
Case…
giuffre-maxwell
gov.uscourts.nysd.447706.57.2
30 pg
…all of which would be consistent with the policy
Case 1:15-cv-07433-RWS Document 57-2 Filed 03/14/16 Page 12 of 30
underlying privilege and with a common sense application of that policy to the
practicalities…
giuffre-maxwell
gov.uscourts.nysd.447706.747.0
27 pg
…Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S RESPONSE IN OPPOSITION TO
DEFENDANT’S MOTION TO EXCLUDE POLICE REPORTS
Sig…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.6
10 pg
…EPSTEIN
---- ---- ---' '
NQN-PRQSECtmQN AQBEIMIW:
IT APPEARING that the City of Palm Beach Police Department and the State
Attomoy's Offlce for the lSth Judicial Circuit in and for Palm Beach Cowity (hereinafter,
the "State Attorney's Office") have conducted an…
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.447706.1201.26
28 pg
…U.S. Showbiz Australia Femail Health Science Money Video Travel Columnists
Latest Headlines News World News Arts Headlines Pictures Most read News Board Wires Login
Police gun battle at We did it and this is Homeland Secu…
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
…
Comments