giuffre-maxwell
gov.uscourts.nysd.447706.1329.0
3 pg
…51 (2d Cir. 2019) (explaining the same).
This Document is akin to a summary exhibit under Federal Rule of
Evidence 1006 — a mere aid prepared by the parties to assist the
Court in carrying out its work. It includes the…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…apparently an
23 affidavit prepared by the FBI that's been provided to
24 Ms. Churcher by someone; I don't know whom, your Honor, but I'm
25 going to presume it was provided to Ms. Churcher by the
…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…a portion of Ms.
Maxwell’s deposition. Exhibit 2 contains a “Flight Log Summary Chart” prepared by Plaintiff’s
counsel and flight logs that contain the names of numerous Non-Party Does. Exhibit 3 purports to
be 88 pages of…
giuffre-maxwell
gov.uscourts.nysd.447706.1087.0
4 pg
…redactions to the Court under seal for in camera review is denied.
As Ms. Maxwell well knows, the Court on July 23 ordered the parties
to prepare the relevant materials for unsealing by today. While
Ms. Maxwell gripes that Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…15 Civ. 7433 (LAP)
Dear Judge Preska:
Paragraph 1 of the Court’s October 28 Order (Doc.998) required the parties to identify
motions decided by the Court and related papers that were sealed or redacted (“Sealed
Materials”). Paragraphs 3…
giuffre-maxwell
gov.uscourts.nysd.447706.949.0
31 pg
…HON. ROBERT W. SWEET,
12
District Judge
13
APPEARANCES
14
BOIES, SCHILLER & FLEXNER LLP
15 Attorneys for Plaintiff
BY: SIGRID S. McCAWLEY
16
HOLLAND & KNIGHT
17 Attorneys for Movant MIAMI HERALD MEDIA CO.
BY…
giuffre-maxwell
gov.uscourts.nysd.447706.79.2
18 pg
…PLAINTIFF’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS
D efend ant,Ghislaine M ax well,by and throu ghheru nd ersigned cou nsel,hereby respond s
to P laintiff’s FirstRequ estforP rod u ction of D ocu ments (the…
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…200 to 250 docket entries, a list of
which the Parties can exchange in advance of briefing and submit to the Court as an attachment to
their briefs with recommendations on a document-by-document basis. Many of these documents…
giuffre-maxwell
gov.uscourts.nysd.447706.1253.0
12 pg
…Plaintiff contests that Doe 17 was named
only by mistake (as opposed to the cited testimony being mistaken only about what her alias was),
and that Does 73 and 93 were not “involved in any of the conduct underlying this…
giuffre-maxwell
gov.uscourts.nysd.447706.1127.0_5
2 pg
…prepare for unsealing (1) the transcripts
of Ms. Maxwell’s and Doe 1’s depositions and (2) all materials
quoting those transcripts or disclosing information from those
transcripts. The documents shall be unsealed in the manner
prescribed by the Court…
giuffre-maxwell
gov.uscourts.nysd.447706.1080.0
2 pg
…represent Plaintiff Virginia Giuffre in this matter and write in response to the Court’s
order directing the parties to prepare for unsealing the documents listed in Exhibit A to Plaintiff’s
Opposition to Defendant Ghislaine Maxwell’s Objections to…
giuffre-maxwell
gov.uscourts.nysd.447706.1196.0
32 pg
…10
Before:
11
HON. LORETTA A. PRESKA,
12
District Judge
13
14 APPEARANCES
15 BOIES SCHILLER & FLEXNER LLP
Attorneys for Plaintiff
16 BY: SIGRID S. McCAWLEY
17 HADDON MORGAN and FOREMAN, P.C.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1220.0
17 pg
…11
HON. LORETTA A. PRESKA,
12
District Judge
13
14 APPEARANCES
15 BOIES SCHILLER & FLEXNER LLP
Attorneys for Plaintiff
16 BY: SIGRID S. McCAWLEY
ANDREW VILLACASTIN
17 SABINA MARIELLA
18 HAD…
giuffre-maxwell
gov.uscourts.nysd.447706.1284.0
17 pg
…HON. LORETTA A. PRESKA,
12
District Judge
13
14 APPEARANCES
15 BOIES SCHILLER & FLEXNER LLP
Attorneys for Plaintiff
16 BY: SIGRID S. McCAWLEY
17 HOLLAND & KNIGHT
Attorneys for Intervenors Julie Brown and Miami Herald
18 …
giuffre-maxwell
gov.uscourts.nysd.447706.1283.0
17 pg
…HON. LORETTA A. PRESKA,
12
District Judge
13
14 APPEARANCES
15 BOIES SCHILLER & FLEXNER LLP
Attorneys for Plaintiff
16 BY: SIGRID S. McCAWLEY
17 HOLLAND & KNIGHT
Attorneys for Intervenors Julie Brown and Miami Herald
18 …
giuffre-maxwell
gov.uscourts.nysd.447706.1026.1
4 pg
…and Protocol for Unsealing Decided Motions
The Court previously ruled that “only motions actually decided by Judge Sweet—along
with documents relevant to Judge Sweet’s decisions on those motions—are properly considered
judicial documents to which a presumption of…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.1
7 pg
…27__,
20202021)
The Court previously ruled that “only motions actually decided by Judge Sweet—along
with documents relevant to Judge Sweet’s decisions on those motions—are properly considered
judicial documents to which a presumption of public access attaches.” Order…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.2
4 pg
…and Protocol for Unsealing Decided Motions
The Court previously ruled that “only motions actually decided by Judge Sweet—along
with documents relevant to Judge Sweet’s decisions on those motions—are properly considered
judicial documents to which a presumption of…
giuffre-maxwell
gov.uscourts.nysd.447706.1108.0
5 pg
…27, 2020)
The Court previously ruled that “only motions actually decided by Judge Sweet—along
with documents relevant to Judge Sweet’s decisions on those motions—are properly considered
judicial documents to which a presumption of public access attaches.” Order…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.0
16 pg
…for Excerpts, and the Non-Party Form
Objection. Counsel conferred with plaintiff’s counsel concerning these proposed revisions,
who object for reasons that they intend to explain to the Court by separate letter.
Ms. Maxwell believes the proposed changes, as…
Comments