giuffre-maxwell
gov.uscourts.nysd.447706.858.0
3 pg
…not
granted Mr. Cernovich intervention under Rule 24(b).
Accordingly, he is not a party of this litigation, and has no standing to bring the instant
opposition. See Esther Sadowsky Testamentary Trust v. Federal Housing Finance Agency, 412
Fed.Appx…
giuffre-maxwell
gov.uscourts.nysd.447706.1105.0
8 pg
…See id.
Nor should it have been. Long-standing law proscribes precisely this kind of post hoc
modification of a protective order. And the rationale for that precedent – especially the
reasonable reliance of non-parties – is cast in stark relief…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.5
4 pg
…
13 A. If Mr. Rizzo was standing right
14 here in front of me, I wouldn't know who he
15 is.
16 Q. Does that mean you are saying that
17 you never met him or simply that you…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.38
8 pg
…Dershowitz intentionally and wrongfully submitted a mi sleading
affidavit to this Court, knowing that Non-Party Virginia Giuffre had a standing objection to the
public disclosure of confidential settlement discussions. Without allowing the Com1 to make a
ruling on privilege…
giuffre-maxwell
gov.uscourts.nysd.447706.239.0
3 pg
…of Columbia. My D.C. Bar number is
426020. I am a member in good standing of the D.C. Bar. The Court granted my application to
appear pro hac vice in the above-referenced matter on June 20, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.223.0
3 pg
…in the District of Columbia. My D.C. Bar number is
426020. I am a member in good standing of the D.C. Bar. My application to appear pro hac vice
in the above-referenced matter is pending.
3. I…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.15_1
4 pg
…correct?
13 A. If was standing right
14 here in front of me, I wouldn't know who he
15 is.
16 Q. Does that mean you are saying that
17 you never met him or simply that you don…
giuffre-maxwell
gov.uscourts.nysd.447706.550.0
3 pg
…rights of the press and of the people at large, as
guaranteed to them under the First Amendment and long-standing traditions of common law
Movant will move this Court for such an order before the Honorable Robert W. Sweet…
giuffre-maxwell
gov.uscourts.nysd.447706.205.0
7 pg
…for Ms. Giuffre’s records. A party has
standing to file a motion to quash a subpoena served on a third party when the party has a
personal right or privilege regarding the subject matter of the subpoena. See, e…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…respectfully write to ask this Court to protect those non-party
interests; a request that is consistent with long-standing Circuit precedent establishing that this
responsibility “rests heavily upon the shoulders” of the district court. In re New York Times…
giuffre-maxwell
gov.uscourts.nysd.447706.207.0
7 pg
…plainly for Ms. Giuffre’s records.
A party has standing to file a motion to quash a subpoena served on a third party when the party
has a personal right or privilege regarding the subject matter of the subpoena. See…
giuffre-maxwell
gov.uscourts.nysd.447706.994.0
14 pg
…J. Doe has not filed a motion to intervene in this matter, nor has he filed a motion to proceed
anonymously. He lacks standing to participate, and his filing should not be considered for that
reason alone. See Dkt. 225…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…Order.
II. Does overstates the reliance interests and the extent to which they would be
frustrated by Dershowitz being granted confidential access to certain materials.
Regardless of whether Doe even has standing to argue reasonable reliance, he grossly
overstates the…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.0
18 pg
…(See DE 290 at 10).
Any “duplicative” litigation filed by Jane Doe 4 would necessarily raise the issue of whether she
has standing under the CVRA under these circumstances.
9
Case 9:08-cv-80736-KAM
Case 1:15-cv…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…Id. There are no such reasons to seal the Epstein Client List,
to the extent clients are identified in the records that remain sealed. Maxwell did not have standing
to raise absent third party privacy concerns. More importantly, even if…
giuffre-maxwell
gov.uscourts.nysd.447706.1062.0
7 pg
…And that need here is reflected in – and accords precisely with
– the long-standing law of this Circuit that (regardless of the parties’ position on the matter) non-
parties retain the right to protection of their privacy and reputational interests…
giuffre-maxwell
gov.uscourts.nysd.447706.96.0
15 pg
…is
“inappropriate” - is perplexing. The US District Court for the Southern District of New York
(SDNY) issued a Standing Order for certain types of cases that is instructive here as it addresses
the discovery of electronically stored information, M10-468…
giuffre-maxwell
gov.uscourts.nysd.447706.185.4
10 pg
…she was not entitled to notification rights under the CVRA. (See DE 290 at 10).
Any “duplicative” litigation filed by Jane Doe 4 would necessarily raise the issue of whether she
has standing under the CVRA under these circumstances.
9
giuffre-maxwell
gov.uscourts.nysd.447706.406.0
31 pg
…Giuffre. He filed his affidavit in the public court
file, despite knowing Ms. Giuffre’s standing objections. He then alerted the media (specifically
the New York Times) to these statements. After Giuffre filed an emergency motion to seal the
affidavit…
giuffre-maxwell
gov.uscourts.nysd.447706.604.0
11 pg
…2016 (Docket No. 250) setting forth how the parties are to file
unredacted documents under seal, and the Standing Order of August 9, 2016 (Docket No. 348).
These orders abrogated the requirements of Section 6.2 of the Electronic Case…
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