giuffre-maxwell
gov.uscourts.nysd.447706.1226.0
4 pg
…contained within the Sealed Records. See DE at
1224, at 5. Plaintiff and Defendant each generously designated materials as confidential under
the Protective Order, and the process of determining what excerpts to unseal from such a
voluminous record is necessarily…
giuffre-maxwell
gov.uscourts.nysd.447706.941.0
6 pg
…filing the document. The only exceptions are if the entire action
has been placed under seal or a judge has signed the sealing envelope and submits
it directly to the sealed records clerk.
See Sealed Records Filing Instructions, U.S…
giuffre-maxwell
gov.uscourts.nysd.447706.1228.0
4 pg
…of our letter, we were directed to the Court’s October 20, 2020
Order, issued in the context of the Court’s consideration of the Sealed Records pertaining to
Does No. 1 and 2. See DE 1157. In that Order…
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.447706.1074.0
18 pg
…P.C., counsel of record for Defendant
Ghislaine Maxwell (“Maxwell”) in this action. I respectfully submit this declaration in
support of Ms. Maxwell’s Reply In Support of Her Objection to Unsealing Sealed Material.
2. Attached as Exhibit A (filed…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.0
56 pg
…Haddon, Morgan & Foreman, P.C., counsel of record for Defendant
Ghislaine Maxwell (“Maxwell”) in this action. I respectfully submit this declaration in
support of Ms. Maxwell’s Objections to Unsealing Sealed Materials Related to Docket
Entries 231, 279, 315, 320…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.44_1
3 pg
…3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of Judith Lightfoot
Redacted Medical Records (Giuffre005431-005438).
4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of Judith
Lightfoot’s June 27…
giuffre-maxwell
gov.uscourts.nysd.447706.1209.0
3 pg
…Haddon, Morgan & Foreman, P.C., counsel of record for Defendant
Ghislaine Maxwell (“Maxwell”) in this action. I respectfully submit this declaration in
support of Ms. Maxwell’s Objections to Unsealing Sealed Materials Related to Docket
Entries 345, 356, 362, 370…
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.447706.1032.0
1 pg
…Maxwell seeks leave of the Court to submit this list under seal because much of its
contents contain references to sealed or redacted materials.
Very truly yours,
Laura A. Menninger
CC: Counsel of Record via ECF
Enclosure (Filed under seal)
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.447706.1198.0
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.447706.1200.12_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.447706.1325.8
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.447706.573.0
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
…2011
Records from Dr. Judith Lightfoot (GUIFFRE005437).
1
Case 1:15-cv-07433-LAP Document 1331-5 Filed 01/05/24 Page 2 of 3
7. Attached hereto as Sealed Exhibit 5 is a true and correct copy of…
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.447706.1200.0_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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