giuffre-maxwell
gov.uscourts.nysd.447706.436.0
15 pg
…Inc. Secs. Litig.,
No. 02 Civ. 4483, 2006 WL 3016311 (S.D.N.Y. Oct. 23, 2006) ....................................... 4
JetBlue Airways Corp. v. Helferich Patent Licensing, LLC,
960 F. Supp. 2d 383 (E.D.N.Y. 2013) ................................................................................ 6
Leucadia, Inc. v…
giuffre-maxwell
gov.uscourts.nysd.447706.1210.0_1
3 pg
…2021
of Ms. Maxwell’s testimony pertaining to private sexual activity
with consenting adults and testimony and identifying information
of non-party Does who have not been considered for unsealing,
the Court considered, as it did during the last round…
giuffre-maxwell
gov.uscourts.nysd.447706.1266.0
4 pg
…Doe.
(Dkt. no. 1264.)
It is well-settled that intervention pursuant to Rule 24(b)
is the proper procedure for a third party to seek to modify a
protective order in a private suit. See United States v. Alex
Brown…
giuffre-maxwell
gov.uscourts.nysd.447706.1118.0
21 pg
…and for Confidential Access to Judicial Records and Discovery Documents (“Motion”) and states
as follows:
INTRODUCTION
The Government seeks to intervene in this five-year old, closed civil defamation action
between two private civil litigants, Plaintiff Giuffre and Defendant Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.813.0
3 pg
…84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is not intended
to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…As for plaintiff Giuffre, she eagerly agreed to a protective order in this case so that she
could wield the judicial machinery as an expansive civil grand jury to extract and coerce
witnesses to reveal private, sensitive and confidential information…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…sexual, or private conduct is described in the
Sealed Materials; and (d) persons who are alleged to have been victimized.
1
Case 1:15-cv-07433-LAP Document 1037-1 Filed 03/26/20 Page 2 of 14
The…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…A hereto (USVI’s operative First Amended Complaint, filed
February 11, 2020). Access to other judicial documents in this action has already been granted
to intervening private parties in interest, see Brown v. Maxwell, 929 F.3d 41 (2d Cir…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.29
4 pg
…84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…or, at a Minimum, After Determination of Summary
Judgment Motion ................................................................................................................. 7
B. Scope of Financial Discovery Must Be Limited to Least Invasion of Private Financial
Affairs, i.e., a Sworn Net Worth Affidavit ...…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.2_1
3 pg
…84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1062.0
7 pg
…the Protective Order. See, e.g., Maxwell, DE 944. That discovery apparently
included probing inquiries on facts and allegations of an intensely private nature. Indeed, as
Judge Sweet observed, this matter involved “allegations concerning the intimate, sexual, and
private conduct…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.1
4 pg
…persons whose intimate, sexual, or private conduct
is described in the Sealed Materials; and (d) persons who are alleged to have been victimized.
1
The Original Parties have been unable to agree on a list of decided motions, as Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.573.0
4 pg
…84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.514.0
3 pg
…84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.20
4 pg
…84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…1 This daytime business address is provided for
identification and correspondence purposes only and is not
intended to imply institutional endorsement by the University of
Utah for this private representation.
Case 1:15-cv-07433-RWS
Case 1:15…
giuffre-maxwell
gov.uscourts.nysd.447706.442.0
4 pg
…58 5-520 2 1
1
This d aytime bu siness ad d ress is provid ed forid entification and correspond ence pu rposes only and is
notintend ed to imply institu tionalend orsementby the University of Utahforthis private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.338.1
4 pg
…84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.949.0
31 pg
…MR. BOHRER: The case has been settled.
5 The second one is the Court was concerned about the
6 revelation of embarrassing information or, worse perhaps I
7 suppose, private information, about the plaintiff. But the
8 plaintiff now, with…
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