giuffre-maxwell
gov.uscourts.nysd.447706.1219.28
3 pg
…21 Page 2 of 3
______
From:
Sent: 10 November 2015 18:16
To: Gmax;
Subject: Fwd: Inquiry from The New York Times
Hi Ghislaine and
Please advise how you wish to respond...
Best
---------- Forwarded message ----------
From: Meier, Barry
Date: Tuesday…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.13
3 pg
…21 Page 2 of 3
______
From:
Sent: 10 November 2015 18:16
To: Gmax;
Subject: Fwd: Inquiry from The New York Times
Hi Ghislaine and
Please advise how you wish to respond...
Best
---------- Forwarded message ----------
From: Meier, Barry
Date: Tuesday…
giuffre-maxwell
gov.uscourts.nysd.447706.47.0
2 pg
…L. GIUFFRE,
Plaintiff,
v. 15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
DECLARATION OF LAURA A. MENNINGER
IN SUPPORT OF D…
giuffre-maxwell
gov.uscourts.nysd.447706.1035.0
2 pg
…Both Plaintiff Virginia Giuffre and Defendant Ghislaine Maxwell have asked for this
Court’s permission to file a List of Decided Motions under seal because the list contains
information that is currently subject to the Sealing Order in this case…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…33.3. Defendant
has served interrogatories that are in direct violation of that Rule because the interrogatories are
not “restricted to those seeking names of witnesses with knowledge of information relevant to
the subject matter of the action, the computation…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…33.3. Defendant
has served interrogatories that are in direct violation of that Rule because the interrogatories are
not “restricted to those seeking names of witnesses with knowledge of information relevant to
the subject matter of the action, the computation…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…33.3. Defendant
has served interrogatories that are in direct violation of that Rule because the interrogatories are
not “restricted to those seeking names of witnesses with knowledge of information relevant to
the subject matter of the action, the computation…
giuffre-maxwell
gov.uscourts.nysd.447706.34.0
3 pg
…L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF
PLAINTIFF’S MOTION TO COMPEL THE PRODUCTION OF DOCUMENTS
SUBJECT TO IMPROPER CLAIM OF…
giuffre-maxwell
gov.uscourts.nysd.447706.55.0
5 pg
…07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF PLAINTIFF VIRGINIA
GIUFFRE’S REPLY IN RESPONSE TO DEFENDANT’S SUPPLEMENTAL RESPONSE
TO MOTION TO COMPEL PRODUCTION OF DOCUMENTS SUBJECT TO
IMPROPER OBJECTIONS
I, Sigrid S…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…33.3. Defendant
has served interrogatories that are in direct violation of that Rule because the interrogatories are
not “restricted to those seeking names of witnesses with knowledge of information relevant to
the subject matter of the action, the computation…
giuffre-maxwell
1320-37
48 pg
…33.3. Defendant
has served interrogatories that are in direct violation of that Rule because the interrogatories are
not “restricted to those seeking names of witnesses with knowledge of information relevant to
the subject matter of the action, the computation…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…33.3. Defendant
has served interrogatories that are in direct violation of that Rule because the interrogatories are
not “restricted to those seeking names of witnesses with knowledge of information relevant to
the subject matter of the action, the computation…
giuffre-maxwell
gov.uscourts.nysd.447706.57.0
4 pg
…v.
Ghislaine Maxwell,
Defendant.
________________________________/
DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF PLAINTIFF VIRGINIA
GIUFFRE’S REPLY IN RESPONSE TO DEFENDANT’S SUPPLEMENTAL RESPONSE
TO MOTION TO COMPEL PRODUCTION OF DOCUMENTS SUBJECT TO
IMPROPER CLAIM OF PRIVILEGE
I, Sigrid S…
giuffre-maxwell
gov.uscourts.nysd.447706.44.0
4 pg
…RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF PLAINTIFF VIRGINIA
GIUFFRE’S CONSOLIDATED REPLY IN SUPPORT OF MOTION TO COMPEL
PRODUCTION OF DOCUMENTS SUBJECT TO IMPROPER OBJECTIONS AND
IMPROPER CLAIM OF PRIVILEGE
I, Sigrid S…
giuffre-maxwell
gov.uscourts.nysd.447706.1103.0
2 pg
…1
Ms. Maxwell’s request is denied. Given that Ms. Maxwell is
not at liberty to disclose this new information because it is
subject to the protective order in the criminal action, (id. at
1), the Court has no reasonable…
giuffre-maxwell
gov.uscourts.nysd.447706.1014.0
3 pg
…emphasizes and, in fact, heavily relies on the fact that the “mere filing of a
paper or document with the court is insufficient to render that paper a judicial document subject to
the right of public access.” Dkt. 1012, at…
giuffre-maxwell
gov.uscourts.nysd.447706.162.2
1 pg
…is admitted to practice Pro Hac Vice in the
above-captioned case in the United States District Court for the Southern District of New York.
All attorneys appearing before this Court are subject to the Local Rules of this Court…
giuffre-maxwell
gov.uscourts.nysd.447706.1321.0
2 pg
…the Court to manage the unsealing process and make its
determinations about what information was to be unsealed. It is, therefore, a judicial document
subject to the public right of access. See United States v. Amodeo, 44 F.3d 141…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.14
3 pg
… Philip Barden
Subject: VR cried rape - prior case dismissed as prosecutors found her 'not credible'
Ghislaine
Some helpful leakage...
In today's Daily Mail print edition and on web
vvww.dailymail.co.uk/news/article-2965360/Prince-Andrew-s-sex…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.2
3 pg
… Philip Barden
Subject: VR cried rape - prior case dismissed as prosecutors found her 'not credible'
Ghislaine
Some helpful leakage ...
In today's Daily Mail print edition and on web
www.dailymail .eo.uk/news/article-2965360/Prince-Andrew-s-sex…
Comments