…See McCawley Decl. at Exhibit 2. Defendant demanded that Ms. Giuffre agree to a Protective Order before Defendant would agree to sit for her deposition. See McCawley Decl. at Exhibit 3, (E-mail from Laura Menninger stating: “We have not…
…15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ REPLY IN SUPPORT OF PLAINTIFF’S MOTION FOR PROTECTIVE ORDER AND TO DIRECT THE DEFENDANT TO DISCLOSE ALL INDIVIDUALS TO WHOM DEFENDANT HAS DISSIMINATED CONFIDENTIAL INFORMATION (DE 335) …
…Under Rule 26(c) of the Federal Rules of Civil Procedure any party may move the court, for good cause shown, for a protective order regarding pretrial discovery “which justice requires to protect a party or person from annoyance, embarrassment…
…the Court explicitly ruled, “[A]ll documents, materials, and information subject to the Protective Order must be returned to the party who designated its confidentiality as of the date this action was dismissed.” Sealed Op., at 3 (Nov. 14, 2017) …
…apparently for further proceedings on what materials are to be sealed. In light of these pending appeals implicating materials covered by the protective order, counsel do not believe that immediate destruction of any materials is required. 1 The underlying motion…
…be sealed. The Non-Parties shall include but are not limited to: (a) persons who produced or answered discovery based upon the representation or understanding that the discovery would be subject to the Protective Order previously issued in this action;…
…Maxwell, Defendant. ____________________________/ DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF PLAINTIFF’S REPLY IN SUPPORT OF PLAINTIFF’S MOTION FOR PROTECTIVE ORDER AND TO DIRECT THE DEFENDANT TO DISCLOSE ALL INDIVIDUALS TO WHOM DEFENDANT HAS DISSIMINATED CONFIDENTIAL INFORMATION (DE 335) I…
…Epstein, Ghislaine Maxwell, and others, certain materials of which have since been filed under seal on this Court’s docket. The late Honorable Robert W. Sweet issued a protective order for the Materials on March 18, 2016. (Dkt. 62). The…
…279, 315, 320 & 335 and to file under seal Exhibit D thereto. The Protective Order governing this case states: Whenever a party seeks to file any document or material containing CONFIDENTIAL INFORMATION with the Court in this matter, it shall…
…Maxwell’s well-founded objections to the release her July 2016 compelled deposition testimony or information concerning various Non-Parties, all of whom relied on the Protective Order issued by the Court. The objections at issue here involve different facts…
…Maxwell to file a redacted Letter to the Court and her proposed redactions to Sealed Materials under seal. The Protective Order governing this case states: Whenever a party seeks to file any document or material containing CONFIDENTIAL INFORMATION with the…
…Protective Order in Giuffre v. Maxwell and therefore has no rights under the same. See August 24, 2020 Letter from Ansari and Cooper in Giuffre v. Dershowitz, ECF No. 171. Regardless, Mr. Doe’s interpretation of the recently-entered Protective…
…be sealed. The Non-Parties shall include but are not limited to: (a) persons who produced or answered discovery based upon the representation or understanding that the discovery would be subject to the Protective Order previously issued in this action;…
…deposition testimony, and other information disclosed pursuant to the disclosure or discovery duties created by the Federal Rules of Civil Procedure. 2. As used in this Protective Order, “document” is defined as provided in FED.R.CIV.P. 34(a…
…file a redacted Reply In Support of Her Objections to Unsealing Sealed Materials and to file under seal Exhibits A-D thereto. The Protective Order governing this case states: Whenever a party seeks to file any document or material containing…
…file a redacted Reply In Support of Her Objections to Unsealing Sealed Materials and to file under seal Exhibits A-D thereto. The Protective Order governing this case states: Whenever a party seeks to file any document or material containing…
…York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION FOR PROTECTIVE ORDER I, Sigri…
…3 THE DOCUMENTS REQUESTED ARE JUDICIAL DOCUMENTS ......................................5 EVEN IF THE DOCUMENTS AT ISSUE ARE NOT "JUDICIAL DOCUMENTS" THE PROTECTIVE ORDER SHOULD HAVE REQUIRED THAT THE PARTIES DEMONSTRATE GOOD CAUSE FOR SEA…
… BACKGROUND Mr. Dershowitz has had several bites at this particular apple. Most recently, Mr. Dershowitz sought modification of the Maxwell protective order (dkt. no. 62 in 15 Civ. 7433) to permit him blanket access to all sealed materials and discovery…
…be sealed. The Non-Parties shall include but are not limited to: (a) persons who produced or answered discovery based upon the representation or understanding that the discovery would be subject to the Protective Order previously issued in this action;…