giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…at 2.
The Reality: Courts routinely seal records concerning underage victims – well beyond
replacing their names with initials – and victims do not forego their rights to privacy
merely because they have played a role in a civil or criminal case…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.35
5 pg
… And so was part of your daily routine to
25 go to your computer and check to see if you had
Case 1:15-cv-07433-LAP Document 1219-35 Filed 07/15/21 Page 4 of 5
Page 224…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.24
6 pg
… And so was part of your daily routine to
25 go to your computer and check to see if you had
MAGNA9 LEGAL SERVICES
Case 1:15-cv-07433-LAP Document 1327-24 Filed 01/05/24 Page 4 of…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.13
5 pg
… And so was part of your daily routine to
25 go to your computer and check to see if you had
MAGNA9 LEGAL SERVICES
Case 1:15-cv-07433-LAP Document 1330-13 Filed 01/05/24 Page 4 of…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.18
6 pg
…A. My computer in my office.
24 Q. And so was part of your daily routine to
25 go to your computer and check to see if you had
Page 224
1 JOHN ALESSI
2 MindSpring messages?
3 A…
giuffre-maxwell
gov.uscourts.nysd.447706.49.0
12 pg
…1990) ................................................. 3
iii
INTRODUCTION
Plaintiff’s response to a routine request for a plain vanilla protective order is both
disturbing and revealing. It is disturbing beca…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…Court and
Ms. Maxwell’s time and needlessly multiply these proceedings.
Courts in this district routinely deny motions based on failure to confer prior to the
motion when such conferral is required by the Rules or Court Order. Prescient Partners…
giuffre-maxwell
gov.uscourts.nysd.447706.343.0
8 pg
…of Time, and
the Southern District of New York Recognizes that Extensions of Time
are Proper where Service through the Hague Requires a Foreign Judicial
Order
Courts routinely grant extensions of time of deadlines when awaiting Hague Convention
service, and…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.4
40 pg
…million.
Despite claiming defamation damages exceeding $80 million, Plaintiff routinely has
stonewalled our efforts to obtain basic information about the nature of the alleged defamation
and the scope of her alleged damages. Plaintiff’s frustration of our discovery efforts has…
giuffre-maxwell
gov.uscourts.nysd.447706.354.0
40 pg
…million.
Despite claiming defamation damages exceeding $80 million, Plaintiff routinely has
stonewalled our efforts to obtain basic information about the nature of the alleged defamation
and the scope of her alleged damages. Plaintiff’s frustration of our discovery efforts has…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…what computer would you use?
A. My computer in my office.
Q. And so was part of your daily routine to go to your computer and check to see if you
had MindSpring messages?
A. No. That was at the…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…Second, the law throughout the
country is clear that routine, raw discovery materials submitted as exhibits to non-dispositive
discovery motions do not convert into “judicial documents” and trigger a right of public access.
The Court should find that these…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.10
469 pg
…I came forward to
14 Maureen Callahan. I went to -- I
15 walked downstairs. I walked around --
16 I have a usual routine that I do. In
17 the morning I went out, I saw the same
18 two people…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…what computer would you use?
A. My computer in my office.
Q. And so was part of your daily routine to go to your computer and check to see if you
had MindSpring messages?
A. No. That was at the…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.7
469 pg
…I came forward to
14 Maureen Callahan. I went to -- I
15 walked downstairs. I walked around --
16 I have a usual routine that I do. In
17 the morning I went out, I saw the same
18 two people…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…what computer would you use?
A. My computer in my office.
Q. And so was part of your daily routine to go to your computer and check to see if you
had MindSpring messages?
A. No. That was at the…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.20
21 pg
…the basis o f relevant and non - specious factual
support . Court intervention should not be invoked to resolve
routine discovery matters on the basis of a supposition of bad
faith. Further filing of frivolous or vexatious motions lacking
sufficient factual…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…what computer would you use?
A. My computer in my office.
Q. And so was part of your daily routine to go to your computer and check to see if you
had MindSpring messages?
A. No. That was at the…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…came forward to Maureen Callahan. I went to – I walked downstairs. I
testified that she is
walked around -- I have a usual routine that I do. In the morning I went
fearful for her life
out, I saw the same…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.43
12 pg
…Br. at 3). But such a routine search
is merely Defendant’s basic obligation under Rule 26 and Rule 34. Ms. Giuffre should not have
been forced to seek a Court Order to get such obviously relevant materials from Defendant…
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