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.447706.1335.7
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.447706.1219.43
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.9
21 pg
…on the basis of 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.447706.1198.5_2
30 pg
…communications with counsel) and her Motion to
Compel for Improper Objections. Even then, Defendant’s counsel refused to even take the
routine step of looking at Defendant’s email and other electronic documents to find responsive
documents, but produced, instead…
giuffre-maxwell
gov.uscourts.nysd.447706.992.0
5 pg
…presumption applies here with full force.
Category 8: Case Management Documents. It is unclear why documents relating to
routine case management issues were ever sealed at all, or what facts could possibly justify their
Case 1:15-cv-07433…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.12_3
30 pg
…communications with counsel) and her Motion to
Compel for Improper Objections. Even then, Defendant’s counsel refused to even take the
routine step of looking at Defendant’s email and other electronic documents to find responsive
documents, but produced, instead…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.13
35 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.447706.1328.9
21 pg
…on the basis of 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.447706.1199.1_1
13 pg
…exists
for the disputed information to be treated as CONFIDENTIAL.
Protective Order at ¶ 11.
The Materials are sensitive in nature, and therefore fall squarely into the categories of
material over which courts routinely grant protection. C.f. Strategic Growth Intern.…
giuffre-maxwell
gov.uscourts.nysd.447706.1240.0
5 pg
…override the public right of access to judicial documents.
For this reason, courts in this Circuit have routinely ordered unsealing of documents even
though the parties in those cases had agreed to protective orders or confidentiality provisions. See,
e.g.…
giuffre-maxwell
gov.uscourts.nysd.447706.1278.0
4 pg
…prevent manifest injustice”).
Courts in this Circuit routinely address these precise concerns by establishing
a prompt deadline for a party to seek a further extension of a stay pending appeal
without imposing a deadline on the Second Circuit to issue…
giuffre-maxwell
gov.uscourts.nysd.447706.1067.0
10 pg
…or sealing order
and provides information in discovery, the information must remain sealed. This is incorrect.
First, courts in this Circuit have routinely ordered unsealing of documents in cases with
protective orders or confidentiality provisions. See, e.g., Gambale v…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…Ransome Dep.) at 36:25-
43:24. The article details multiple things, including that Mr. Epstein has routinely settled out of
court many civil cases brought against him by various women. See Menninger Decl., Ex. B.
After reading the article…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.15
43 pg
…the party must file a motion, "setting forth a reasonable basis for departing from the
general policy of a public filing," and courts in this district routinely grant parties' motions to file
under seal for good cause. See e.g…
giuffre-maxwell
gov.uscourts.nysd.447706.1028.0
5 pg
…an
evidentiary hearing, subject to this Court’s discretion whether to grant it. Litigants
shouldering an evidentiary burden routinely have the right to request an evidentiary
hearing, subject to the court’s discretion whether to grant it. This proceeding should…
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