giuffre-maxwell
gov.uscourts.nysd.447706.1320.14
3 pg
…constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.2
3 pg
…constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you…
giuffre-maxwell
1320-14
3 pg
…constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…wherein he used his vast wealth and property holdings and a deliberately opaque web of
corporations and companies to transport young women and girls to his privately-owned islands
where they were held captive and subject to severe and extensive…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.28_4
5 pg
…constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you…
giuffre-maxwell
gov.uscourts.nysd.447706.370.0
17 pg
…Id.at RFP 25, 27, 28, 29, 30, and 31.
real estate or personal property in which she holds an interest; Id. at RFP 20, 26, and 36.
loans or statements of indebtedness to or from Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.19
17 pg
…Id.at RFP 25, 27, 28, 29, 30, and 31.
real estate or personal property in which she holds an interest; Id. at RFP 20, 26, and 36.
loans or statements of indebtedness to or from Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.13
22 pg
…696, 716 (1983) (Brennan, J.
concurring). It thus “protects two different interests of the citizen—the interest in retaining
possession of property and the interest in maintaining personal privacy.” Id. (cleaned up). “A
seizure threatens the former, a search the…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…2016). Thus, Ms. Maxwell’s decision to sell the
property, made long before this litigation, by definition could not have been informed by this
litigation or demonstrate “consciousness” of guilt or civil liability.
Second, Plaintiff’s claim that information regarding…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…as RANSOME_000001-000016, which should be treated as
Confidential pursuant to the parties’ Protective Order.
4. All Communications You have had in whatever form with any other female who you ever
witnessed at or in a property, home, business…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…INTERVENE AND UNSEAL
1
Case 1:15-cv-07433-LAP Document 1259 Filed 07/28/22 Page 2 of 17
TABLE OF CONTENTS
MEMORANDUM OF LAW ..................................................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.9
6 pg
…constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…as RANSOME_000001-000016, which should be treated as
Confidential pursuant to the parties’ Protective Order.
4. All Communications You have had in whatever form with any other female who you ever
witnessed at or in a property, home, business…
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…1071], at 3.)
Under the terms of the order, discovery materials properly marked
confidential pursuant to the protective order “shall not be
disclosed or used for any purpose except the preparation and trial
of [Giuffre v. Maxwell],” (Protective Order ¶ 4…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…sensitive subjects
without it being disclosed to the public, absent an additional
order of this Court. The Protective Order served "to protect the
discovery and dissemination of confidential information or
information which will properly annoy, embarrass, or oppress any
party…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…as RANSOME_000001-000016, which should be treated as
Confidential pursuant to the parties’ Protective Order.
4. All Communications You have had in whatever form with any other female who you ever
witnessed at or in a property, home, business…
giuffre-maxwell
gov.uscourts.nysd.447706.1122.0_2
13 pg
…trafficking enterprise in the Virgin Islands, wherein he used his vast wealth and property
holdings and a deliberately opaque web of corporations and companies to transport young
women and girls to his private islands, where they were held captive and…
giuffre-maxwell
gov.uscourts.nysd.447706.551.0
17 pg
…B/A CERNOVICH MEDIA’S
MOTION TO INTERVENE AND UNSEAL
TABLE OF CONTENTS
TABLE OF AUTHORITIES ........................................................................................................ III
MEMORANDUM OF LAW ...............................................…
giuffre-maxwell
gov.uscourts.nysd.447706.371.2
18 pg
…conferral.
DOCUMENT REQUEST NO. 26
Produce all deeds and titles to all real property owned by You or held on Your behalf
either directly or indirectly at any time from January 2015 to the present.
RESPONSE: Ms. Maxwell objects to…
giuffre-maxwell
gov.uscourts.nysd.447706.898.0
4 pg
…and
this Court have all consistently emphasized that “[w]hat transpires in the court room is public
property,” and “[o]ne of the demands of a democratic society is that the public should know what
goes on in courts.” Katzman…
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