giuffre-maxwell
gov.uscourts.nysd.447706.79.2
18 pg
…of the RelevantP eriod s d escribed in paragraph15,supra and is
withhold ingd ocu ments within the RelevantP eriod thatare private and are notreasonably
calcu lated to lead to the d iscovery of ad missible evid ence.
Document Request…
giuffre-maxwell
gov.uscourts.nysd.447706.148.0
9 pg
…No basis exists for
the Plaintiff, a private litigant who has publicly disclosed volumes of information related to her
allegations, to claim that letters or emails from her lawyers or other documents sent to any law
enforcement agency are protected…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…#335), and states as follows:
INTRODUCTION
Plaintiff does not want to make public police reports which already are public and are
freely available to any private citizen, media outlet or company who lodges a simple request with
the relevant law…
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.447706.949.0
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1083.0
3 pg
…other alleged victims, or facilitated such
acts, (c) persons whose “intimate, sexual, or private conduct is described in the Sealed
Materials,” and (d) persons who allegedly have been victimized. Id. at 1.
The parties conferred on July 29, 2020. Plaintiff…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.1
7 pg
…sexual, or private conduct
is described in the Sealed Materials; and (d) persons who are alleged to have been victimized.
3
Case 1:15-cv-07433-LAP Document 1232-1 Filed 10/29/21 Page 3 of 7
The…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.2
4 pg
… (c) persons whose intimate, sexual, or private conduct
1
The Original Parties have been unable to agree on a list of decided motions, as Defendant Maxwell excluded two
decided motions (Dkts. 468 & 567) from the list she previously submitted to…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…to assist the Court in conducting its review.
A. Judge Sweet Observed That The Sealed Materials Implicate Non-Parties
And Include Non-Adjudicated Claims On Non-Public, Private Matters.
We represent John Doe. Doe is not, and has never been…
giuffre-maxwell
gov.uscourts.nysd.447706.1182.0_1
3 pg
…As such, the Dershowitz Protective Order may fatally undermine this Court’s carefully
constructed measures designed to protect from unnecessary public disclosure sensitive and
private non-party information in the Maxwell materials.
After rejecting multiple attempts by Mr. Dershowitz to…
giuffre-maxwell
gov.uscourts.nysd.447706.264.0
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.
2
…
giuffre-maxwell
gov.uscourts.nysd.447706.1108.0
5 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 1108 Filed 08/27/20 Page 2 of 5
The Non…
giuffre-maxwell
gov.uscourts.nysd.447706.721.0
3 pg
…84112
(801) 585-5202 1
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.447706.1199.6_1
14 pg
…#335), and states as follows:
INTRODUCTION
Plaintiff does not want to make public police reports which already are public and are
freely available to any private citizen, media outlet or company who lodges a simple request with
the relevant law…
giuffre-maxwell
gov.uscourts.nysd.447706.1191.0_1
3 pg
…this Court recognized in its January 19 order, the limited presumption of
access applicable to these discovery filings was overcome by Ms. Maxwell’s interest in
keeping private the details of her own consensual, sexual activity. TR 1/19/2021…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…abuse of discretion,
the Second Circuit in dicta “describe[d] certain methods courts can employ to” prevent records
from being used to “gratify private spite or promote public scandal” or “serve as reservoirs of
libelous statements for press consumption.” Brown…
giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…51 n.40. Notably the
Second Circuit in Brown held that redactions of sensitive, private information disclosed by
witnesses in depositions because of “a strong expectation of continued confidentiality.”
Brown, 929 F.3d at 48 n.22.
D. Prevention of…
giuffre-maxwell
gov.uscourts.nysd.447706.1196.0
32 pg
…cv-07433-LAP Document 1196 Filed 01/27/21 Page 7 of 32 7
1 transcript is outweighed by Ms. Maxwell's countervailing
2 interests in resisting disclosure of the details of her
3 private, intimate relationships with consenting adults…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…84112
(801) 585-520216
16
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.
10
…
giuffre-maxwell
gov.uscourts.nysd.447706.1220.0
17 pg
…Article 3 powers. The Court
4 keeps this somewhat less substantial public presumption in mind
5 in determining whether it is outweighed by any private
6 interests in sealing.
7 As to the countervailing interests proffered,
8 Ms. Maxwell has…
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