giuffre-maxwell
gov.uscourts.nysd.447706.49.0
12 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.920.0
2 pg
…for the Second Circuit from
the Order dated May 2, 2017 and filed on May 3, 2017 (ECF No. 892), which construed
Cernovich Media’s Motion to Unseal (ECF No. 550) as a motion to modify the protective order
and…
giuffre-maxwell
gov.uscourts.nysd.447706.829.0
4 pg
…cause a
privacy harm to the designating party.” Doc.062 ¶ 8. If a non-designating party
disagrees with a “confidential” designation, it is entitled under the Protective
Order to object, giving notice identifying the information subject to the
objection. Id. …
giuffre-maxwell
gov.uscourts.nysd.447706.436.0
15 pg
…SUPPORT OF PROPOSED
INTERVENOR ALAN M. DERSHOWITZ’S MOTION FOR PERMISSIVE
INTERVENTION AND UNSEALING OF JUDICIAL DOCUMENTS, OR IN THE
ALTERNATIVE MODIFICATION OF PROTECTIVE ORDER
Emery Celli Brinckerhoff & Abady LLP
600 Fifth Avenue, 10th Floor
…
giuffre-maxwell
gov.uscourts.nysd.447706.1015.0
4 pg
…19 Page 2 of 4
The Honorable Loretta A. Preska
December 12, 2019
Page 2
protective order with Intervenors’ counsel to allow Intervenors to meaningfully participate in the
briefing on sealing.
ARGUMENT
I. Notice of Maxwell’s December 5, 2019…
giuffre-maxwell
gov.uscourts.nysd.447706.1312.0
9 pg
…basis that the celebrity status of Michael Jackson would make portions of the record “subject
to sensational media accounts”). Whether a protective order is in place does not negate the public’s
right to access the documents. See Rotger v…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.8
10 pg
…serving a Notice of Deposition. Defendant filed a
1
Case 1:15-cv-07433-LAP Document 1330-8 Filed 01/05/24 Page 2 of 10
Motion for Protective Order trying to avoid her deposition. After a hearing on…
giuffre-maxwell
gov.uscourts.nysd.447706.230.0
19 pg
…Maxwell has issued subpoena for records from all of these accounts. Plaintiff had filed a motion for protective
order, and thus is still trying to prevent access to relevant discovery.
7
Case 1:15-cv-07433-LAP Document 230…
giuffre-maxwell
gov.uscourts.nysd.447706.956.0
3 pg
…case –
has been the victim of one-sided and selective leaking of materials, with no recourse because of
the existence of this Court’s protective and sealing orders. We ask that the Court immediately
convene a conference with counsel for…
giuffre-maxwell
gov.uscourts.nysd.447706.1240.0
5 pg
…aff’d, 671 F.2d 212 (6th Cir. 1982) (“It is not a ground
for a protective order as suggested by deponents’ counsel, that the depositions contain hearsay
answers or answers whose relevancy or competency might be suspect. The test…
giuffre-maxwell
gov.uscourts.nysd.447706.68.0
17 pg
…attempt to convince Ms.
Giuffre to disclose her address confidentially, pursuant to the Protective Order.
11
Case 1:15-cv-07433-LAP Document 68 Filed 03/23/16 Page 15 of 17
F. Defendant Is Not Prejudiced And She…
giuffre-maxwell
gov.uscourts.nysd.447706.551.0
17 pg
…Litig., 164 F.R.D. 346,
351 (S.D.N.Y. 1996) (granting intervention as of right to newspaper to seek modification of
protective order and access to documents in judicial proceeding); and see Kelly v. City of New
York…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…asked
for more specific details about what information Ms. Maxwell hoped to elicit from
Ms. Churcher, Maxwell’s counsel stated that she could not share any further details in light of
the protective order entered in this case. Id. ¶ 3.
…
giuffre-maxwell
gov.uscourts.nysd.447706.555.0
21 pg
…that's uRJn the.d ouds now,,
bonfire.
I
I A. Yes.
Q. And you wrote that journal in order to collect your thoughts?
I A. To get everything out of here and on to a er.
I Menninger Deel.…
giuffre-maxwell
gov.uscourts.nysd.447706.15.0
29 pg
…District Court Judge Marra denied
Plaintiff’s Joinder Motion, ordered the portions of the Joinder Motion pertaining to non-parties
2
Although the Complaint does not explicitly mention the 2011 Statement, it appears Plaintiff believes it to
be the “additional…