giuffre-maxwell
gov.uscourts.nysd.447706.1070.0
1 pg
…TRANSCRIPT
FRQIHUHQFH
Notice is hereby given that an official transcript of a ________________ held on __________________
has been filed by the court reporter/transcriber in the above-captioned matter.
Redaction responsibilities apply to t…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.17
12 pg
…2016. Ms. Maxwell has twice sat for deposition, approaching 13
hours on the record, far more than the presumptive 7 hour limit under the Federal Rules. During
that time, Plaintiff has had a full and fair opportunity to depose Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1255.0
1 pg
…4/19/22
Notice is hereby given that an official transcript of a ________________ held on __________________
has been filed by the court reporter/transcriber in the above-captioned matter.
Redaction responsibilities apply to the attorneys of record or pro se parties…
giuffre-maxwell
gov.uscourts.nysd.447706.1197.0_1
1 pg
…1/19/21
Notice is hereby given that an official transcript of a ________________ held on __________________
has been filed by the court reporter/transcriber in the above-captioned matter.
Redaction responsibilities apply to the attorneys of record or pro se parties…
giuffre-maxwell
gov.uscourts.nysd.447706.230.0
19 pg
…1
I. PLAINTIFF’S PRODUCTION OF KEY DOCUMENTS AFTER HER DEPOSITION
NECESSITATES ADDITIONAL EXAMINATION ............................................................. 3
A. Plaintiff failed to identify her health care providers and produce their records prior to
her deposition, despite this Court’s or…
giuffre-maxwell
gov.uscourts.nysd.447706.1022.0
1 pg
…5(1&(
Notice is hereby given that an official transcript of a ________________ held on __________________
has been filed by the court reporter/transcriber in the above-captioned matter.
Redaction responsibilities apply to the attorneys of record or pro se parties…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.15
14 pg
…2
I. PLAINTIFF’S PRODUCTION OF KEY DOCUMENTS AFTER HER DEPOSITION
NECESSITATES ADDITIONAL EXAMINATION ............................................................. 2
A. Plaintiff failed to identify her health care providers and produce their records prior to
her deposition, despite this Court’s order …
giuffre-maxwell
gov.uscourts.nysd.447706.32.0
1 pg
…hereby given that an official transcript of a proceeding type held on date
proceeding held has been filed by the court reporter/transcriber in the above-captioned matter.
Redaction responsibilities apply to the attorneys of record or pro se parties…
giuffre-maxwell
gov.uscourts.nysd.447706.551.0
17 pg
…Access ............................................................................... 4
2.1.2 The First Amendment Compels Access .................................................................. 5
2.2 Standard for Sealing a Court Record .....................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.981.0
2 pg
…Mr. Cernovich's goal in unsealing the
Maxwell records was to give the Jeffrey Epstein network the attention it deserved. Mr.
Cernovich had informed many members of the press that Epstein had escaped justice,
with little to no interest from…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.46
14 pg
…2
I. PLAINTIFF’S PRODUCTION OF KEY DOCUMENTS AFTER HER DEPOSITION
NECESSITATES ADDITIONAL EXAMINATION ............................................................. 2
A. Plaintiff failed to identify her health care providers and produce their records prior to
her deposition, despite this Court’s order …
giuffre-maxwell
gov.uscourts.nysd.447706.1312.0
9 pg
…justify the sealing of judicial documents, courts must “review the documents
individually and produce ‘specific, on-the-record findings that sealing is necessary to preserve
higher values.’” Brown, 929 F.3d at 48 (quoting Lugosch, 435 F.3d at 124…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…Instruction and states as follow:
INTRODUCTION
Plaintiff continues in her course of re-litigating issues, multiplying these proceedings and
misstating the record. In what amounts to the fourth Motion on forensic examination of Ms.
Maxwell’s computers and email accounts…
giuffre-maxwell
gov.uscourts.nysd.447706.1240.0
5 pg
…and
incorporate their prior arguments in support for unsealing (Dkts. 1214, 1155, 1067). 1
ARGUMENT
There is no basis in the record for this Court to continue to seal any of the documents
concerning Does 17, 53, 54, 56, 73…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.12
15 pg
…Blando Court Reporting & Video, Inc.
1 INDEX OF EXHIBITS
2
INITIAL
3 DESCRIPTION REFERENCE
4
Exhibit 1 Authorization for the Release 7
5 and Disclo…
giuffre-maxwell
gov.uscourts.nysd.447706.1029.0
2 pg
…2020, the Court ruled on the merits of the list and
excluded the two motions that Plaintiff contends were decided by Judge Sweet. But the record is
clear that Judge Sweet “decided” both of these motions. Dkts. 468 & 567.
As…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.18
8 pg
…1 - CONFIDENTIAL
2 A. No, sir, I do not.
3 Q. Do you remember that the police officers
4 tape-recorded the statement with you?
5 A. Vaguely, yes.
6 Q. Do you remember how old you were when you
…
giuffre-maxwell
gov.uscourts.nysd.447706.54.0
11 pg
…Ms. Maxwell was obligated by British
law to set the record straight and to defend herself by issuing a denial of Giuffre’s claims about
her and pointing out that her more fantastical stories contained obvious lies.
5. Giuffre filed…
giuffre-maxwell
gov.uscourts.nysd.447706.956.0
3 pg
…met Ms. Roberts – and, as an investigation by
former FBI director Louis Freeh concluded, records prove that Mr. Dershowitz could not have
abused Ms. Roberts because he was not present in the places where she claims such abuse
occurred. Notwithstanding…
giuffre-maxwell
gov.uscourts.nysd.447706.1042.0
2 pg
…that which has already been sealed for far too long. She further fundamentally
mischaracterizes the role of the media in seeking access to court records: The media are not
distinguishable from the public; they are the surrogates for the public…