…the police reports demonstrate Plaintiff’s tumultuous home life, bearing no relationship to any press statements or alleged defamation and providing alternative causation to any of Plaintiff’s now-claimed emotional distress. It makes perfect sense that Plaintiff would want…
…the police reports demonstrate Plaintiff’s tumultuous home life, bearing no relationship to any press statements or alleged defamation and providing alternative causation to any of Plaintiff’s now-claimed emotional distress. It makes perfect sense that Plaintiff would want…
…careers, and personal relationships. Counsel is thus reminded of the human cost of inadvertently disclosing the names and identifying information of Does who should have remained under seal. If counsel requires further clarification on the Court’s December 18 Order…
…the district court did not rely on it in granting the motion; (3) finding that as to parts of defendant Ghislaine Maxwell’s deposition concerning her sexual relationships with consenting adults, her privacy interests outweighed any presumption of public access…
…the district court did not rely on it in granting the motion; (3) finding that as to parts of defendant Ghislaine Maxwell’s deposition concerning her sexual relationships with consenting adults, her privacy interests outweighed any presumption of public access…
…p 7:7–10 (“Ms. Maxwell’s interest in keeping private the details of her sexual relationships with consenting adults warrants the sealing of those portions of her testimony (and any materials that reference them).”). In the July 2016 deposition,…
…16 Filed 01/27/21 Page 6 of 12 Case 1:15-cv-07433-LAP Document 1199-16 Filed 01/27/21 Page 7 of 12 her close relationship with Jeffrey Epstein and plotted with him to defame Ms…
…referred to three times. That Doe's 22 relationship with Jeffrey Epstein has been the subject of 23 intense media coverage and Doe 183's name has appeared in 24 numerous places in unsealing portions of Ms. Maxwell's criminal…
…referred to three times. That Doe's 22 relationship with Jeffrey Epstein has been the subject of 23 intense media coverage and Doe 183's name has appeared in 24 numerous places in unsealing portions of Ms. Maxwell's criminal…
…adviser. 3 It's not clear again because of the redactions when this 4 transformation presumably took place. But the reality is that 5 that is simply an incorrect characterization of the 6 relationship. 7 Since 2011, and continuing up…
…that she “cried rape” when she was 14. 5 Case 1:15-cv-07433-LAP Document 1335-5 Filed 01/09/24 Page 7 of 12 her close relationship with Jeffrey Epstein and plotted with him to defame Ms…
…access or a social media account. It is not possible to overstate the close relationship between the documents plaintiff wants to unseal in this case and the criminal prosecution the government is pursuing next door. Indeed one of the very…
…damage Ms. Giuffre’s reputation. They also reveal that Defendant’s defamatory statements are not “substantially true.” The joint defense agreement(s) show Defendant’s ongoing and continued relationship with Dershowitz and Epstein, which is relevant to her defenses. Both…
…actual malice at the time of any publication. Plaintiff’s argument for relevance is nonsense. She claims the JDA might show “the nature of the ongoing relationship between Ms. Maxwell and her “co-conspirator” and between Ms. Maxwell and Mr…
…production. REPLY ARGUMENT I. Communications between Plaintiffs and Giuffre prior to the formation of the attorney-client relationship in March 2014 are not protected by the attorney- client privilege. As an initial matter, any communications between …
…all communications including Pottinger be submitted to the Court for in camera review to determine if the nature of the relationship and/or communications are in his capacity as an attorney and the primary purpose of the communication was the…
…any compelling reason to continue to keep their identities hidden. In fact, Doe 1 and Doe 2’s names, as well as their relationships with Jeffrey Epstein and Ghislaine Maxwell, have already been widely publicized, weighing against continued sealing. See…
…27/21 Page 7 of 32 7 1 transcript is outweighed by Ms. Maxwell's countervailing 2 interests in resisting disclosure of the details of her 3 private, intimate relationships with consenting adults. This 4 testimony is, in any case…
…In the limited instances where this Court has found that sealing remains appropriate, it has been quite narrow and limited to information about intimate sexual relationships with consenting adults, medical records,2 and the names of minor victims. Now that…
…need to coordinate with 3 counsel. Of course the three arm, purple hair example is one, 4 but there is ample public information about relationships 5 between people and the like that, if not redacted, could cause 6 a nonparty…