giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…
intervenor Dershowitz; and intervenors Julie Brown and Miami Herald (collectively “Miami
Herald”). So they present more or less similar arguments. We request leave to address their three
separate briefs in a single reply brief. We submit this will be more…
giuffre-maxwell
gov.uscourts.nysd.447706.895.0
3 pg
…GIUFFRE,
Plaintiff,
v. 15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
Declaration Of Laura A. Menninger In Support Of Defendant’s
Response in…
giuffre-maxwell
gov.uscourts.nysd.447706.1003.0
1 pg
…A]ll of the documents in question are judicial documents, and accordingly the
entire record should be unsealed, subject to redactions similar to what the Second Circuit applied.”).
Giuffre objects, however, to the selective unsealing that would occur if only…
giuffre-maxwell
gov.uscourts.nysd.447706.232.1
…of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil
Rule 33.3, and therefore…
giuffre-maxwell
gov.uscourts.nysd.447706.1058.1
3 pg
…Likewise, third-party witnesses from whom Professor Dershowitz has
sought discovery have already or are expected to raise similar objections. Professor Dershowitz
has explained that he is prepared to abide by any applicable court order subject only to reserving
the…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.17
12 pg
…subjects covered by the emails. Moreover, despite having access to other email
communications that are similar in nature and substance to the two email communications
Plaintiff now claims are “key” documents, Plaintiff elected to not examine Ms. Maxwell on those
…
giuffre-maxwell
gov.uscourts.nysd.447706.1285.0
6 pg
…any details about her ordeals two decades
ago, she unquestionably continues to experience trauma similar to that of at least one
other Non-Party Doe whose privacy and identity this Court protected with Plaintiff
Virginia Guiffre’s consent. See Doc…
giuffre-maxwell
gov.uscourts.nysd.447706.1134.0_5
2 pg
…similar to other
conclusory assertions this Court has rejected in the past.
Maxwell also asserts that the Court should stay the unsealing process because “the Second
Circuit’s ruling regarding the appeal was issued late in the day” on Monday…
giuffre-maxwell
gov.uscourts.nysd.447706.1286.0
6 pg
…any details about her ordeals two decades
ago, she unquestionably continues to experience trauma similar to that of at least one
other Non-Party Doe whose privacy and identity this Court protected with Plaintiff
Virginia Guiffre’s consent. See Doc…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.16
10 pg
…expert
witness she must carry the affirmative burden on proving: 1) Plaintiff “attempt[ed] to secure the
voluntary [trial] attendance of a witness who lives beyond the subpoena power of the court” and
2) that no similar expert is available…
giuffre-maxwell
gov.uscourts.nysd.447706.87.0
4 pg
…s Motion to Compel.
9. Ms. Maxwell anticipates filing a similar opposition to the appearance of
Bradley Edwards, who just filed a motion to appear pro hac vice, and would ask that it be
contemporaneously with the other motions on…
giuffre-maxwell
gov.uscourts.nysd.447706.604.0
11 pg
…judgment
pleadings, counsel for Plaintiff filed yet another action in this District against Defendant
Ghislaine Maxwell (“Maxwell”), as well as Jeffrey Epstein, based on allegations similar to those
in this case. See Jane Doe 43 v. Jeffrey Epstein, et al…
giuffre-maxwell
gov.uscourts.nysd.447706.408.0
13 pg
…include any detailed facts about her abuse. Weeks went by and the
Government – as it had done on a similar request for a stipulation to add another victim – did not
respond to counsel’s request for a stipulation.
9. Finally…
giuffre-maxwell
gov.uscourts.nysd.447706.26.1
26 pg
…had publicly
defamed her in statements made by individuals operating
at his direction or within scope of their employment. Cases that cite this headnote
Complaint was subsequently amended to include similar
claims by two additional plaintiffs. Defendant moved to
dismiss.
…
giuffre-maxwell
gov.uscourts.nysd.447706.140.2
3 pg
…3
The court must calibrate the need of a litigant for information with the government’s duty to try to prevent similar
occurrences and to maintain the public peace and welfare.4 Among the governmental or public interests that may…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.25
9 pg
… Let me correct myself. I
21 believe only one had.
22 Q. And was that -- was that one of similar
23 age to the other girls?
24 MR. PAGLIUCA: Object to form and
25 foundation.
Case 1:15-cv-07433…
giuffre-maxwell
gov.uscourts.nysd.447706.102.0
9 pg
…and now
Defendant’s Motion to Compel Disclosure of Criminal Investigation, or Alternatively, Motion to Stay
[DE 101], all requesting a stay of her deposition or similar relief. Defendant’s deposition has been
scheduled for March 2, 2016, March 25…
giuffre-maxwell
gov.uscourts.nysd.447706.57.2
30 pg
…group (the AON group), used the final
form draft CAA as a starting point for the drafting of a similar document which they put
forward in their bid to devise and operate a scheme for Powerhouse. In doing so they…
giuffre-maxwell
gov.uscourts.nysd.447706.925.0
2 pg
…No. 17 Civ. 616, which is based on allegations
similar to those made in the Giuffre Matter. The evidence at issue was produced by Jane Doe 43 ,
a non-party in the Giuffre Matter. Judge Koeltl, before whom the Ja~e…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.11
18 pg
… Let me correct myself. I
21 believe only one had.
22 Q. And was that -- was that one of similar
23 age to the other girls?
24 MR. PAGLIUCA: Object to form and
25 foundation.
MAGNA9 LEGAL SERVICES
Case 1…