giuffre-maxwell
gov.uscourts.nysd.447706.1256.23
4 pg
7. Attached hereto as Sealed Composite Exhibit 5 are true and correct copies of
Excerpts from the June 1, 2016 Deposition of John Alessi.
8. Attached hereto as Sealed Exhibit 6 is a true and correct copy of June 20…
giuffre-maxwell
gov.uscourts.nysd.447706.739.0
3 pg
…in Limine to Permit Questioning Regarding Plaintiff’s Sexual History and
Reputation.
3. Attached hereto as Sealed Composite Exhibit 1 are true and correct copies of
.
4. Attached hereto as Sealed Exhibit 2 is a…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…Dec. 16,
2019 (DE 1016). Such materials are referred to herein as the “Sealed Materials” or “Sealed
Items.” The Sealed Materials will be enumerated in a List of Decided Motions designated by the
Court. In accordance with Brown v. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1032.0
1 pg
…Ms. Maxwell has clarified (a) which pages are included in each Sealed Exhibit,
and (b) which of those pages were released in their entirety by the 2nd Circuit.
Counsel for Ms. Maxwell has conferred with Plaintiff’s counsel and believes…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.0_2
1 pg
…and January 26, 2021 (ECF No. 1193),
Plaintiff files the documents ordered unsealed listed in Exhibit F to Defendant’s Reply
Memorandum of Law in Further Support of Objections to Unsealing Sealed Materials Related to
Docket Entries 231, 279, 315…
giuffre-maxwell
gov.uscourts.nysd.447706.1034.0
16 pg
…PRESKA, Senior United States District Judge:
The Court has considered the parties’ various submissions
regarding the review protocol (“the Protocol”) to be utilized by
the Court in its individualized review of the sealed materials at
issue in this litigation. (See…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.0
1 pg
…and January 26, 2021 (ECF No. 1193),
Plaintiff files the documents ordered unsealed listed in Exhibit F to Defendant’s Reply
Memorandum of Law in Further Support of Objections to Unsealing Sealed Materials Related to
Docket Entries 231, 279, 315…
giuffre-maxwell
gov.uscourts.nysd.447706.1278.0
4 pg
…recently retained undersigned counsel in the United States to file
a narrow appeal in opposition to the release of certain sealed materials containing
information that has not previously been disclosed and is likely to cause her to suffer
irreparable harm…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.12_1
4 pg
…as Exhibit 1 is a true and correct copy of July 29, 2016,
Correspondence from Ty Gee.
4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of Excerpt from
April 22, 2016, Deposition of Ghislaine Maxwell.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1301.0
1 pg
…Maxwell attach hereto their joint chart identifying all non-objecting Does.
The parties have redacted only limited identifying information about certain Does, and will submit
a sealed version of the chart contemporaneously with this filing.
Respectfully,
…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.0
18 pg
…GIUFFRE,
Plaintiff,
v. 15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
Declaration Of Laura A. Menninger In Support Of Ms. Maxwell’s
Rep…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.8
4 pg
…for Failure to Comply with Court Order and Failure to
Comply with Rule 26(a).
3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of Excerpts from
the May 18, 2016 Deposition of Rinaldo Rizzo.
4…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.1
4 pg
…16,
2019 (DE 1016). Such materials are referred to herein as the “Sealed Materials” or “Sealed
Item.” The Sealed Materials will be enumerated in a List of Decided Motions designated by the
Court .1 In accordance with Brown v. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.573.0
4 pg
…in Limine to Exclude Expert Testimony and Opinion of
Professor Terry Coonan.
3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of
.
4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.5
3 pg
…submit this Declaration in Support of Plaintiff’s Response In
Opposition To Defendant’s Motion For Sanctions.
3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of September 2,
2008, Victim Notification Letter (GIUFFRE001203-GIUFFRE001205).
4.
…
giuffre-maxwell
gov.uscourts.nysd.447706.514.0
3 pg
…Support of Plaintiff’s Response In
Opposition To Defendant’s Motion For Sanctions.
3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of
4. Attached hereto as Sealed Exhibit 2 is a true and correct copy…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.0
56 pg
…X
...
............................................
VIRGINIA L. GIUFFRE,
Plaintiff,
v. 15-cv-07433-LAP
GHISLAINE MAXWELL,
Defendant.
-------------…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.0_2
1 pg
…and January 26, 2021 (ECF No. 1193),
Plaintiff files the documents ordered unsealed listed in Exhibit F to Defendant’s Reply
Memorandum of Law in Further Support of Objections to Unsealing Sealed Materials Related to
Docket Entries 231, 279, 315…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.6_2
4 pg
…b) &(c) Sanctions for Failure to Comply with Court Order and Failure to
Comply with Rule 26(a).
3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of Excerpts from
the May 18, 2016 Deposition of .
…
giuffre-maxwell
gov.uscourts.nysd.447706.1194.0_6
2 pg
…reason to revisit those arguments.
Third, Defendant’s note that certain testimony should be kept sealed so that she can
challenge its admissibility at her criminal trial is not only speculative, but has also already been
addressed by this Court…
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