giuffre-maxwell
gov.uscourts.nysd.447706.1105.0
8 pg
…Court regarding unsealing, the Court’s protocol and legal
precedent dictate that the absence of such participation should not factor negatively into the
Court’s balancing of considerations – as it is ultimately the responsibility of this Court, and not
the…
giuffre-maxwell
gov.uscourts.nysd.447706.408.0
13 pg
…Since July 2008, I have been involved in important and precedent-setting crime
victims’ rights litigation in the Southern District of Florida trying to protect the rights of various
victims under the Crime Victims’ Rights Act (CVRA), 18 U.S…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.1
13 pg
…Since July 2008, I have been involved in important and precedent-setting crime
victims’ rights litigation in the Southern District of Florida trying to protect the rights of various
victims under the Crime Victims’ Rights Act (CVRA), 18 U.S…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.45
13 pg
…Since July 2008, I have been involved in important and precedent-setting crime
victims’ rights litigation in the Southern District of Florida trying to protect the rights of various
victims under the Crime Victims’ Rights Act (CVRA), 18 U.S…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…confidence in the administration of justice.”). Indeed, the motion to intervene is
devoid of any citations to precedent that allows an individual to exploit these bedrock legal
principles solely for his personal benefit, rather than the public at large. Furthermore…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.38
8 pg
…is well within this Court's province to award severe sanctions against him. Mr. Dershowitz's
deliberate and willful behavior is sufficient under the contro lling precedent for this Court to strike
his pleadings in this case. Mercer v. Raine…
giuffre-maxwell
gov.uscourts.nysd.447706.46.0
22 pg
…subject matter” of the communications. Plaintiff cites three cases from the Southern District of
15
New York, describes them as “controlling precedent” and demands an in camera review of the
subject documents.
First, Ms. Maxwell’s privilege log satisfies the…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…25
weights of presumption based on the extent to which they were relied
upon in resolving [a] motion [for summary judgment].”18
Second, in contravention of our precedent, the District Court
failed to review the documents individually and produce “specific…
giuffre-maxwell
gov.uscourts.nysd.447706.406.0
31 pg
…confidence in the administration of justice.”). Indeed, the motion to intervene is
devoid of any citations to precedent that allows an individual to exploit these bedrock legal
principles solely for his personal benefit, rather than the public at large. Furthermore…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.14_2
40 pg
…in that
case held that any finding of waiver should be made with “caution.” Id. at 228.
Rather than cite this controlling Second Circuit precedent, Defendant relies on a 2002
case from this Court applying the Hearn “at issue” doctrine…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…and useful in the judicial process in order for it to be designated a judicial
document.
Id. Brown was building on Amodeo I’s holding when it said, “As our precedent makes clear, a
court “‘perform[s] the judicial function’ . …
giuffre-maxwell
gov.uscourts.nysd.447706.997.0
5 pg
…Otherwise Improper Content Are Non-Judicial
Plaintiff does not appear to contest that filings with frivolous, scandalous, or otherwise
improper content, which is predicated on the express language of governing precedent. See, e.g.,
Lugosch, 435 F.3d at 122…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.22
31 pg
…confidence in the administration of justice.”). Indeed, the motion to intervene is
devoid of any citations to precedent that allows an individual to exploit these bedrock legal
principles solely for his personal benefit, rather than the public at large. Furthermore…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…25
weights of presumption based on the extent to which they were relied
upon in resolving [a] motion [for summary judgment].”18
Second, in contravention of our precedent, the District Court
failed to review the documents individually and produce “specific…
giuffre-maxwell
gov.uscourts.nysd.447706.978.0
27 pg
…2527
weights of presumption based on the extent to which they were relied
upon in resolving [a] motion [for summary judgment].”18
Second, in contravention of our precedent, the District Court
failed to review the documents individually and produce “specific…
giuffre-maxwell
gov.uscourts.nysd.447706.1005.0
6 pg
…and useful in the judicial process in order for it to be
designated a judicial document.
Id. Brown was building on Amodeo I’s holding when it said, “As our precedent makes clear, a
court “‘perform[s] the judicial function’ . …
giuffre-maxwell
gov.uscourts.nysd.447706.977.0
27 pg
…25
weights of presumption based on the extent to which they were relied
upon in resolving [a] motion [for summary judgment].”18
Second, in contravention of our precedent, the District Court
failed to review the documents individually and produce “specific…
giuffre-maxwell
gov.uscourts.nysd.447706.1349.0
31 pg
…those documents individually for possible unsealing. We agree that no such
categorical conclusion was warranted. To the extent that error may be
attributable to any lack of clarity in this court’s precedents, see January 2020
Order, 2020 WL 133570…
giuffre-maxwell
gov.uscourts.nysd.447706.589.0
24 pg
…indeed, offer any explanation at all) as to why some unspecified interested in
publicly revealing documents concerning the sexual assault of minors should take precedence
over the well-reasoned Protective Order this Court not only entered but repeatedly reaffirmed.
D…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…serve Mr. Epstein by alternate means.
Mot. at 2; Doc. # 160.8
Plaintiff apparently now claims that she never received that email from Martin Weinberg.
All of the preceding communications, however, indicate that Mr. Weinberg promptly responded
to Ms. McCawley…