giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…above-captioned action
pursuant to Rule 24 of the Federal Rules of Civil Procedure and
(2) should intervention be permitted, for confidential access to
sealed judicial records and discovery documents. (See Notice of
Ex Parte Motion to Intervene and for …
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…her response chart that she objected to unsealing her medical
records. (DE 1073 at 19-20) Without explanation, the Court presumably recognized that
plaintiff relied on the Protective Order when disclosing confidential materials, kept sealed
numerous records related to Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…publicly
disseminate such reports? Where did she obtain these reports? Was it “theft” of “sealed juvenile
records” for her to have those police reports?
It would seem the juveniles referenced in the reports filed by Plaintiff, juveniles who
have never…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.17
25 pg
…when, and by whom such reports (or descriptions of reports) were
obtained from a minor child’s sealed juvenile records and files.
RESPONSE: Ms. Maxwell objects to this Request in that there is no “Interrogatory No.
1” to which the…
giuffre-maxwell
1320-17
25 pg
…when, and by whom such reports (or descriptions of reports) were
obtained from a minor child’s sealed juvenile records and files.
RESPONSE: Ms. Maxwell objects to this Request in that there is no “Interrogatory No.
1” to which the…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.6_1
14 pg
…publicly
disseminate such reports? Where did she obtain these reports? Was it “theft” of “sealed juvenile
records” for her to have those police reports?
It would seem the juveniles referenced in the reports filed by Plaintiff, juveniles who
have never…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.8
29 pg
…false accusations. In the same article, Plaintiff’s counsel Sigrid McCawley’s claimed Plaintiff
was “‘victimized all over again with [the New York Daily News’ access to] the leak of sealed
juvenile records.’” Id. (GM_00121) (emphasis supplied). Notably neither…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 26 of 40
request as it seeks documents of sealed juvenile records, and the only means of obtaining
such records are either through court order or illegal means…
giuffre-maxwell
gov.uscourts.nysd.447706.71.3
40 pg
…15-cv-07433-RWS Document 71-3 Filed 03/23/16 Page 26 of 40
request as it seeks documents of sealed juvenile records, and the only means of obtaining
such records are either through court order or illegal means…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.1
18 pg
…documents concerning how, when, and by whom such reports (or descriptions of
reports) were obtained from a minor child’s sealed juvenile records and files.
Response: Ms. Maxwell objects to this Request in that there is no “Interrogatory No. 1”…
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.447706.1122.0_2
13 pg
…IN SUPPORT OF EX PARTE MOTION
TO INTERVENE AND FOR CONFIDENTIAL ACCESS TO
JUDICIAL RECORDS AND DISCOVERY DOCUMENTS
Case 1:15-cv-07433-LAP Document 1122 Filed 09/24/20 Page 2 of 13
The Government of the United…
giuffre-maxwell
gov.uscourts.nysd.447706.1092.0
1 pg
…2020 (ECF No. 1091), Plaintiff is filing
renewed versions of the materials previously sealed at ECF Nos. 235-13 and 249-13 as attachments
hereto.
Sincerely,
/s/ Sigrid S. McCawley
Sigrid S. McCawley,…
giuffre-maxwell
gov.uscourts.nysd.447706.1003.0
1 pg
…request for pre-Answer discovery,
Giuffre expects that she will also be allowed to identify and publish sealed materials in response
to Dershowitz’s forthcoming counterclaims.
Sincerely,
/s/ Sigrid McCawley
…
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.447706.1073.0
22 pg
…Notably, many of the documents were sealed in the first instance at the
request of Plaintiff and her counsel. And as to, for example, Plaintiff’s medical records, no one
interposed any objection to their unsealing until Plaintiff’s belated…
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.447706.1090.0_1
1 pg
…164, 172 199, and
230 (ECF No. 1068-1), as attachments hereto.
Plaintiff will file “Ms. Maxwell’s and Doe 1’s deposition transcripts and any sealed
materials that quote or disclose information from them . . . on Monday, August 3, 2020…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.38
8 pg
…EDWARDS, and CASE NO. CACE 15-000072
PAUL G. CASSELL,
Plaintiffs,
v.
ALAN DERSHOWITZ,
Defendant.
SEALED, UNREDACTED SUPPLEMENTAL MOTION TO STRIKE AND FOR
SANCTIONS
Non-Party Virginia Giuffre, by and through undersigned counsel, hereby moves …
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