giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…parties that should remain permanently sealed. 1 First,
discovery materials, including written responses and deposition transcripts, or excerpts of the
same, that were not relevant to the performance of Article III functions, are not judicial records,
are entitled to no…
giuffre-maxwell
gov.uscourts.nysd.447706.1046.0
3 pg
…multiple times to propose five motions pertaining to J. Doe 1 and J. Doe 2, as
identified on the sealed Non-Party List, with which the Court may begin administering the Order
and Protocol for Unsealing Decided Motions, Dkt. 1044…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…On June 20, 2016, this Court
Ordered Defendant to sit for a second deposition because her refusal to answer questions posed
in her first Deposition (June 20, 2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…On June 20, 2016, this Court
Ordered Defendant to sit for a second deposition because her refusal to answer questions posed
in her first Deposition (June 20, 2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,…
giuffre-maxwell
gov.uscourts.nysd.447706.1285.0
6 pg
…unsealing order to remain consistent with its treatment of other Non-Party
Does who continue to experience trauma as a result of the events that are the subject
of this litigation by “keeping [her] name sealed in excerpts that discuss …
giuffre-maxwell
gov.uscourts.nysd.447706.1335.3
223 pg
…marked confidential, sealed,
22 and retained by the Special Master.
23
24
25
CONFIDENTIAL
Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 5 of 223
4
1 Dep…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…On June 20, 2016, this Court
Ordered Defendant to sit for a second deposition because her refusal to answer questions posed
-
in her first Deposition (June 20, 2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,…
giuffre-maxwell
gov.uscourts.nysd.447706.1286.0
6 pg
…unsealing order to remain consistent with its treatment of other Non-Party
Does who continue to experience trauma as a result of the events that are the subject
of this litigation by “keeping [her] name sealed in excerpts that discuss …
giuffre-maxwell
gov.uscourts.nysd.447706.1218.1
17 pg
…On June 20, 2016, this Court
Ordered Defendant to sit for a second deposition because her refusal to answer questions posed
in her first Deposition (June 20, 2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.12
223 pg
…187
21
REPORTER'S NOTE: Exhibit 5 marked confidential, sealed,
22 and retained by the Special Master.
23
24
25
CONFIDENTIAL
4
1 Deposition taken before Deborah A. Harris,
2 …
giuffre-maxwell
gov.uscourts.nysd.447706.1331.12
10 pg
…3560022
~1gn Mc aw1ey, t,sq.
s111ccawlevPbstllp.com
January 30, 2017
…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.17
12 pg
…at Exhibit 9, Excerpted Dep. Ex. 1 (flight records evidencing
Defendant (GM) flying with Ms. Giuffre).
7
See McCawley Decl. at Exhibit 10, “All aboard the ‘Lolita Express’: Flight logs reveal the
many trips and Alan Dershowitz took on pedophile…
giuffre-maxwell
gov.uscourts.nysd.447706.363.0
18 pg
…in the pleadings. While Ms. Giuffre’s attorneys could have made the filings under seal (as
much of the case file is sealed already), they elected to make the accusations against me part of
the public record, intending, I believe…
giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…on-the-record findings that sealing is necessary to preserve
higher values.’” Brown, 929 F.3d at 48 (quoting Lugosch, 435 F.3d at 124). “The burden of
demonstrating that a document submitted to a court should be sealed rests…
giuffre-maxwell
gov.uscourts.nysd.447706.1021.0
18 pg
…That's a different issue.
14 There is a third category that I think I might propose
15 to your Honor. We were the only party to submit a request to
16 keep documents sealed and we, in our chart…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…all); see also McCawley Decl. at Exhibit 6, Excerpted Rodgers Dep.
Ex. 1 (flight records evidencing Defendant (GM) flying with Ms. Giuffre
12
See McCawley Dec. at Sealed Composite Exhibit 5, David Rodgers’ June 3, 2016 Dep. Tr. at
18…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.4
21 pg
…action accrued and three years before the start of this litigation,1 and because Ms. Giuffre
could not find a notebook in which she recorded her dreams, an item for which there is no
evidence of having evidentiary value whatsoever…
giuffre-maxwell
gov.uscourts.nysd.447706.851.0
158 pg
…undisclosed, and through a FOIA record, and through the
6 articles to allege that he wasn't on the island.
7 And so in your Honor's order in 264-1, which is one of
8 the sealed orders, you…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.7
12 pg
…at Exhibit 9, Excerpted Rodgers Dep. Ex. 1 (flight records evidencing
Defendant (GM) flying with Ms. Giuffre).
7
See McCawley Decl. at Exhibit 10, “All aboard the ‘Lolita Express’: Flight logs reveal the
many trips Bill Clinton and Alan Dershowitz…
giuffre-maxwell
gov.uscourts.nysd.447706.561.0
22 pg
…only knew that the
statements were false but indeed actively participated in fabricating false
statements. The record is completely devoid of evidence to support the existence
of any such basis.
McCawley Dec., Exhibit 2 (Summary Judgment Motion) at 12.
Ultimately…
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