giuffre-maxwell
gov.uscourts.nysd.447706.148.0
9 pg
…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 by any privilege. Plaintiff lacks standing to raise the issue and
…
giuffre-maxwell
gov.uscourts.nysd.447706.885.0
7 pg
…cv-07433-LAP Document 885 Filed 05/02/17 Page 3 of 7
Ms. Giuffre’s previous Requests for Production,1 they contain Court-ordered search terms, and
they are not protected by any privilege, work product or otherwise. Accordingly…
giuffre-maxwell
gov.uscourts.nysd.447706.79.2
18 pg
… M s.M ax wellobjects to the Requ ests to the ex tentthey seekd ocu ments or
information protected by the attorney/clientprivilege,the work-prod u ctd octrine,Ru le 40 8 of the
Fed eralRu les of E…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…Statutes
Plaintiff also cites Colorado statutes which, she claims, support the proposition that her
identity as the victim of domestic violence is protected by Colorado law. It is not. Section 13-
90-107(k),3 is a testimonial privilege statute…
giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…2007) (“[A]
person’s status as a juvenile sex abuse victim is clearly the type of ‘highly personal’ information
that we have long recognized as protected by the Constitution from governmental dissemination
absent a substantial government interest in disclosure.”).
Moreover…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…reporting while, on the other, her own privacy should be protected.
Plaintiff also wants to keep confidential numerous records because they concern
“information about events when plaintiff was a minor.” See DE 1156-1 at Lines re. 381-1, 381…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.0
35 pg
…on the Protective Order when she sat for and
responded to questions during the July 2016 deposition,” and that her testimony is therefore
protected from disclosure under “the Second Circuit’s case law governing access to judicial
documents.” Maxwell Br…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…4 So we are awaiting a ruling. We believe those
5 individuals should be protected under the Court's protective
6 order and those names kept confidential during the course of
7 this, and it is my understanding that defendants…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…Id. The protective order
should not be vacated or modified “to accommodate the Government’s desire to inspect
protected testimony for possible use in a criminal investigation, either as evidence or as the
subject of a possible perjury charge.” Id…
giuffre-maxwell
gov.uscourts.nysd.447706.949.0
31 pg
…Supreme Court case, which holds: "Personal
24 sexual conduct is a fundamental right protected by the right to
25 privacy."
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
I59YGIUC
Case 1:15-cv-07433-LAP Document 949 Filed 06…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…Plaintiff’s reply, contains numerous quotes from the protected deposition
testimony taken from Non-Party Does and should remain sealed based on countervailing interests
discussed above.
7. Reasonable reliance on a protective order by a party or non-party (CI…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…the notification and objection procedure is unnecessary because,
(i) under Plaintiff’s proposal, victims would be fully protected by having their names and
identifying information redacted, and (ii) there is no articulable value in allowing the often wealthy
and powerful…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
… The Court of Appeals’ Stated Concern For The Publication Of Libelous
Statements Protected By The Litigation Privilege Emphasizes This Court’s
Responsibility To Protect The Interests Of Non-Parties.
While the Court of Appeals ultimately found Judge Sweet erred in…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.6_1
14 pg
…Statutes
Plaintiff also cites Colorado statutes which, she claims, support the proposition that her
identity as the victim of domestic violence is protected by Colorado law. It is not. Section 13-
90-107(k),3 is a testimonial privilege statute…
giuffre-maxwell
gov.uscourts.nysd.447706.892.0
11 pg
…the importance of leaving these
materials protected by the Protect i ve Order outweighs any public
interest in their publication at this time .
The Intervenor seeks to modify the Protective Order
with respect to documents produced in discovery and referred…
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