giuffre-maxwell
gov.uscourts.nysd.447706.1187.0
3 pg
…DERSHOWITZ,
Defendant.
LORETTA A. PRESKA, Senior United States District Judge:
The Court is in receipt of a letter from counsel to a non-
party Doe (dkt. no. 1182 in 15-cv-7433) raising concerns that
that protective order recently entered…
giuffre-maxwell
gov.uscourts.nysd.447706.960.0
1 pg
…10007
Re: Giuffre v. Maxwell,
Case No.: 15-cv-07433-RWS
Dear Judge Sweet,
We are in receipt of Intervenor Dershowitz’s letter (DE 956) filed on December 3, 2018.
Intervenor Dershowitz has made serious allegations against Plaintiff and her…
giuffre-maxwell
gov.uscourts.nysd.447706.1154.0_5
3 pg
…of any Sealed Materials. The solicitation
and receipt of objections from Non-Parties who wish to participate is intended
merely to aid the Court in balancing privacy and other interests against the
public’s right of access. The Court will…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.33
3 pg
…virus checker and procedures. No responsibility is accepted by ACUITY Reputation
Limited for loss or damage arising from the receipt or use of this e-mail.
This email is intended for the addressee named within only. It may contain legally…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.27
3 pg
…virus checker and procedures. No responsibility is accepted by ACUITY Reputation
Limited for loss or damage arising from the receipt or use of this e-mail.
This email is intended for the addressee named within only. It may contain legally…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.9
6 pg
…virus checker and procedures. No responsibility is accepted by ACUITY Reputation
Limited for loss or damage arising from the receipt or use of this e-mail.
This email is intended for the addressee named within only. It may contain legally…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.14
3 pg
…checked for viruses, you
should rely on your own vims checker and procedures. No responsib ility is accepted by ACUITY Reputation
Limited for loss o r damage arising from the receipt or use of this e-mail.
CONFIDENTIAL GM_00577
giuffre-maxwell
gov.uscourts.nysd.447706.1326.2
3 pg
…been checked for viruses, you
should rely on your own virus checker and procedures. No responsibility is accepted by ACU ITY Reputation
Limited for loss or damage arising from the receipt or use of this e-mail.
CONFIDENTIAL GM_00577
giuffre-maxwell
1320-14
3 pg
…checked for viruses, you
should rely on your own vims checker and procedures. No responsib ility is accepted by ACUITY Reputation
Limited for loss o r damage arising from the receipt or use of this e-mail.
CONFIDENTIAL GM_00577
giuffre-maxwell
gov.uscourts.nysd.447706.1200.13_1
3 pg
…memoranda, mobile phone agreements, wire
transfer receipts, or any other document that concerns Plaintiff in any way,
whether or not they reference her by name.” Plaintiff is asking defendant to
Meredith Schultz
Paul Cassell
July 29, 2016
Page 2
produce…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.0
18 pg
…of Ms. Maxwell’s Reply In Support of Her Objection to Unsealing Sealed Material.
2. Attached as Exhibit A (filed under seal) are true and correct copies of the certified
mail return receipts for J. Doe 1 and J. Doe…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.5_1
3 pg
…mobile phone agreements, wire
transfer receipts, or any other document that concerns Plaintiff in any way,
whether or not they reference her by name.” Plaintiff is asking defendant to
Case 1:15-cv-07433-LAP Document 1199-5 Filed 01…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…address available for the nonparty in a
public records database or other readily available source. Service shall be effected via
first class certified mail, return receipt requested. After service, the party causing the
service shall file a certificate of service…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…in any sequence, and (B) discovery by one party does not
require any other party to delay its discovery.”). Likewise, receipt of Ms. Maxwell’s Rule 26
disclosures in February also had nothing to do with these witnesses. Id. Notably…
giuffre-maxwell
gov.uscourts.nysd.447706.1105.0
8 pg
…any
Sealed Materials. The solicitation and receipt of objections from
Non-Parties who wish to participate is intended merely to aid the
Court in balancing privacy and other interests against the public’s
right of access. The Court will conduct…
giuffre-maxwell
gov.uscourts.nysd.447706.1353.0
6 pg
…not the Government—when she ordered that
the protective order be modified to allow Boies Schiller to provide the Materials to the Government
and did not impose any additional or reciprocal obligations on the Government upon receipt of
those materials…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…are.
a. There is no evidence that Doe 1 received or read the Notice from the Court,
nor even that Doe 1 is still living. The return receipt was signed for by someone other than
Doe 1. Ex. A.
b…
giuffre-maxwell
gov.uscourts.nysd.447706.1034.0
16 pg
…address available for the nonparty in a
public records database or other readily available source. Service shall be effected via
first class certified mail, return receipt requested. After service, the party causing the
service shall file a certificate of service…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.20
21 pg
…parties are further
directed to jointly file a proposed redacted version of this
Opinion or notify the Court that none are necessary with in two
weeks of the date of receipt of this Opin i on .
It is so ordered .
…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…supplied).
As to the latter, many Non-Parties never received a copy of the Protocol Notice; receipt
of the Notice to nearly half of the 91 Non-Parties to whom Ms. Maxwell attempted service was
never confirmed; plaintiff’s counsel…
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