giuffre-maxwell
gov.uscourts.nysd.447706.1034.0
16 pg
…to “identify[] the most current address available for
[a non-party] in a public records database or other readily
available source.” This will ensure that the notice to non-
parties is “the best practicable under the circumstances.”
Guevoura Fund Ltd…
giuffre-maxwell
gov.uscourts.nysd.447706.370.0
17 pg
…life and finances from 2015 to present, including all documents “related
to” her:
tax returns, W-2 or any other source of income statements for her or any entity in which
she holds an interest; Id. at RFP 23…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.19
17 pg
…life and finances from 2015 to present, including all documents “related
to” her:
tax returns, W-2 or any other source of income statements for her or any entity in which
she holds an interest; Id. at RFP 23…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…Sealed Materials to
be considered to be served confidentially with a Non-Party Notice approved by the Court.
“Best efforts” entails identifying the most current address available for the nonparty in a
public records database or other readily available source…
giuffre-maxwell
gov.uscourts.nysd.447706.1105.0
8 pg
…protocol requires the parties to “use their best efforts” to notify non-parties, which
it defines as “identifying the most current address available for the nonparty in a public records
database or other readily available source.” DE 1044 ¶ 2(b)…
giuffre-maxwell
gov.uscourts.nysd.447706.1100.1
13 pg
…1:20-cr-00330-AJNDocument
Document1100-1
36 Filed
Filed
07/30/20
08/10/20Page
Pag…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…TGP
highlights that it is addressing this gap as a trusted news source for the stories and views that are
largely untold or ignored by traditional news outlets.5 One of its core values is that it “must have
courage…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.3
21 pg
…at 7 ¶ 30.
Lest there be any doubt as to the source of this information, Barden specifically added
that the source was “entirely” his client – the Defendant: “The content of the statement was
entirely based on information I acquired in…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…at least one
press source claimed to “crack” the redactions to identify witnesses and potential testimony by or
3
https://www.npr.org/2020/10/22/926590153/jeffrey-epstein-update-read-the-deposition-that-
ghislaine-maxwell-fought-to-hide
4…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.0
16 pg
…Sealed Materials to
be considered to be served confidentially with a Non-Party Notice approved by the Court.
“Best efforts” entails identifying the most current address available for the nonparty in a
public records database or other readily available source…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.1
7 pg
…no. 1044) and has been approved by the Court. “Best efforts” entails
identifying the most current address available for the nonparty in a public records
database or other readily available source. Service shall be effected via first class certified
mail…
giuffre-maxwell
gov.uscourts.nysd.447706.1100.0
16 pg
…1:20-cr-00330-AJNDocument
Document1100-1
36 Filed
Filed
07/30/20
08/10/20Page
Pag…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.6
134 pg
…read it back? 15 foundational issues. We don't know the
16 MR. CASSELL: I can just give it to 16 source of any information that would be
17 you. 17 responsive to the question. It could
18 MR. PAGLIUCA:…
giuffre-maxwell
gov.uscourts.nysd.447706.26.1
26 pg
…Mot. to Dismiss, Ex. D at 1, hereinafter
paraphernalia, speaks for itself. “November 21, 2014 Statement.”)
As the old saying goes, “consider the source.”
(Decl. re: Mot. to Dismiss, Ex. F at 1, hereinafter D. Washington Post Statement, November 22…
giuffre-maxwell
gov.uscourts.nysd.447706.1044.0
13 pg
…Notice is attached hereto and has been approved by the Court. “Best efforts” entails
identifying the most current address available for the nonparty in a public records
database or other readily available source. Service shall be effected via first class
…
giuffre-maxwell
gov.uscourts.nysd.447706.1338.1
134 pg
…read it back? 15 foundational issues. We don't know the
16 MR. CASSELL: I can just give it to 16 source of any information that would be
17 you. 17 responsive to the question. It could
18 MR. PAGLIUCA:…
giuffre-maxwell
gov.uscourts.nysd.447706.371.2
18 pg
…relating to
Virginia Roberts Giuffre that exists within the public domain, the internet or in public court
records and which are equally available to both parties and can be obtained from some other
source that is more convenient, less burdensome…
giuffre-maxwell
gov.uscourts.nysd.447706.1108.0
5 pg
…no. 1044) and has been approved by the Court. “Best efforts” entails identifying the most
current address available for the nonparty in a public records database or other readily
available source. Service shall be effected via first class certified mail…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…Dershowitz has not even identified
any specific work product he claims to need, much less shown why he cannot get the underlying
information from another source. The Court should disregard Dershowitz's assertions that
Cassell and Edwards waived their work…
giuffre-maxwell
gov.uscourts.nysd.447706.436.0
15 pg
…Law § 79-h(c), only “professional journalists and
newscasters,” and protects information that “is not obtainable from any alternative source.” The fact that Ms.
Giuffre is the source of the Emails thus defeats any claim of privilege. Similarly, the qualified…
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