giuffre-maxwell
gov.uscourts.nysd.447706.1296.16
2 pg
…order (ECF No. 701-1), be unsealed and/or de-designated—an action that would
require modification of the Protective Order in this case —the Court also simultaneously unseal
Intervenor’s June 21, 2017 letter and its attachments, and remove…
giuffre-maxwell
gov.uscourts.nysd.447706.110.0
7 pg
…antitrust and copyright law in Spinelli,
there is one, simple defamation claim based upon Defendant’s widely-publicized statements.”).
A case cannot simultaneously be both simple and complex.1
In deciding Ms. Maxwell’s Motion to Stay Discovery (Doc # 18…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.17
16 pg
…confidentiality designation concerning the Ransome deposition—an action
that would require modification of the Protective Order in this case —it also simultaneously
remove the confidentiality designation from several related emails and attachments that the
parties previously designated confidential (RANSOME_000273…
giuffre-maxwell
gov.uscourts.nysd.447706.111.2
5 pg
…The parties confirmed to the Court that
they have simultaneously proceeded with merits and class discovery as directed by the Court at
the Initial Conference.
Case 1:15-cv-07433-LAPDocument
Case 2:13-cv-06329-LDW-AKT Document…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.7
21 pg
…Phillip Esplin. She simultaneously files her
specific objections to portions of these and other depositions designated by Plaintiff. She further
states as follows:
INTRODUCTION
Plaintiff has filed deposition designations for 14 witnesses for use in her case in chief at…
giuffre-maxwell
gov.uscourts.nysd.447706.408.0
13 pg
…1,500 pages of largely irrelevant materials to the victims (DE
225-1 at 5), while simultaneously submitting 14,825 pages of relevant materials under seal to the
Court. The Government claimed that these pages were “privileged” for various reasons,…
giuffre-maxwell
gov.uscourts.nysd.447706.1129.0_5
2 pg
…Any such remedy would be sought within 24-48 hours,
and the conferral between counsel for the parties regarding redactions would occur
simultaneously because counsel is fully aware of this Court’s desire not to have any “last-
minute disputes.”
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…Maxwell is filing simultaneously with this Response a Motion to Re-Open Plaintiff’s Deposition.
2
Case 1:15-cv-07433-LAP Document 1320-28 Filed 01/03/24 Page 6 of 32
BACKGROUND
To divert attention away from…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…opposite.
5. In doing so, Mr. Cassell seeks to accomplish two goals simultaneously:
first, to suppress information—the Requested Documents—which exculpates me from the
charges of sexual misconduct, while allowing Ms. Giuffre and her allies to publicly disseminate
those…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.4_1
29 pg
…Through these multiple litigations and
representations, they attempt to strategically leverage attorney-client communications and
attorney work product to their tactical advantage by selectively disclosing information.
Simultaneously, they desperately seek to avoid disclosure of related materials they know are
unfavorable…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…Maxwell is filing simultaneously with this Response a Motion to Re-Open Plaintiff’s Deposition.
2
Case 1:15-cv-07433-LAP Document 1256-12 Filed 05/03/22 Page 6 of 32
Case 1:15-cv-07433-LAP…
giuffre-maxwell
gov.uscourts.nysd.447706.164.0
29 pg
…Through these multiple litigations and
representations, they attempt to strategically leverage attorney-client communications and
attorney work product to their tactical advantage by selectively disclosing information.
Simultaneously, they desperately seek to avoid disclosure of related materials they know are
unfavorable…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
…opposite.
5. In doing so, Mr. Cassell seeks to accomplish two goals simultaneously:
first, to suppress information—the Requested Documents—which exculpates me from the
charges of sexual misconduct, while allowing Ms. Giuffre and her allies to publicly disseminate
those…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.50
15 pg
…Epstein]’.” Dershowitz Decl.,
Ex. M at 8 (emphasis added).
1
Case 1:15-cv-07433-LAP Document 1218-50 Filed 07/15/21 Page 6 of 15
simultaneously shielding those documents from public view. The courts are presumptively
public…
giuffre-maxwell
gov.uscourts.nysd.447706.179.0
22 pg
…Giuffre to spend time and resources on unnecessary motion
practice, while simultaneously wasting judicial resources. The Court should not indulge
Defendant’s attempts to imprint the Court’s prior ruling -- addressing a wholly different set of
underlying facts -- onto this…
giuffre-maxwell
gov.uscourts.nysd.447706.946.0_1
14 pg
…the problem with such an order:
[E]ach party could circumvent the "good cause" standard for
protection and simultaneously shift the burden to his adversary to
unseal a document while benefitting from the more rigorous
"extraordinary circumstances" standard that would…
giuffre-maxwell
gov.uscourts.nysd.447706.63.0
22 pg
…R. CIV. P. 26
As detailed in the simultaneously filed pleading, Plaintiff has failed to properly make
disclosures pursuant to Rule 26(a)(1). While these disclosures may not directly impact the
subject matter of Defendant’s depositions, they demonstrate…
giuffre-maxwell
gov.uscourts.nysd.447706.634.0_2
15 pg
…for a
7 deposition, and we do not have time going forward to both do
8 that and simultaneously engage in the very complicated,
9 rigorous pretrial depressed schedule that we have set between
10 now and March 13th. If…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…about 1,500 pages of irrelevant materials to the victims (DE 225-1 at 5), while simultaneously
submitting 14,825 pages of relevant materials under seal to the Court. The Government claimed
that these pages were “privileged” for various reasons…
giuffre-maxwell
1320-28
32 pg
…Maxwell is filing simultaneously with this Response a Motion to Re-Open Plaintiff’s Deposition.
2
Case 1:15-cv-07433-LAP Document 1320-28 Filed 01/03/24 Page 6 of 32
BACKGROUND
To divert attention away from…