giuffre-maxwell
gov.uscourts.nysd.447706.363.6
15 pg
…1, New York Daily News, April
7, 2015. Defendant has subjected Jane Doe No. 3 to horrific public attacks including publicly
calling her a “prostitute” and a “bad mother” to her three minor children. See Exhibit 2, Local 10
News…
giuffre-maxwell
gov.uscourts.nysd.447706.1083.0
3 pg
…(Doc. 1044).1 Nonparties on the
list include (a) persons who produced or answered discovery based on the understanding that
such discovery would be subject to the Protective Order, (b) persons who are identified as
allegedly having engaged in sex…
giuffre-maxwell
gov.uscourts.nysd.447706.438.0
1 pg
…stipulates to the motion to the extent that it asks for a Court order directing her to
produce the agreement, subject to the confidentiality order previously entered in this case. Ms.
Giuffre asks for the Court to endorse this letter…
giuffre-maxwell
gov.uscourts.nysd.447706.201.0
5 pg
…13/16 Page 2 of 5
identified individuals who may have relevant information about the matters at issue in this case.
Certain of those individuals have been the subject of sexual abuse or were witnesses to events
involving the abuse…
giuffre-maxwell
gov.uscourts.nysd.447706.26.1
26 pg
…false; (3) defamatory, meaning damaging
another person’s earlier defamatory remark to good reputation of person who is subject of
generally gives rise to separate cause of action statement; (4) made by actor with requisite
for defamation against original defamer…
giuffre-maxwell
gov.uscourts.nysd.447706.829.0
4 pg
… 8. If a non-designating party
disagrees with a “confidential” designation, it is entitled under the Protective
Order to object, giving notice identifying the information subject to the
objection. Id. ¶ 11.
Case 1:15-cv-07433-LAP Document 829 Filed…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.44
4 pg
…in
Colorado and avoid service, but we found her and we served her and now she'll be subjected to a
deposition," he said.
"And if she repeats what she said previously under oath, she will go to jail because…
giuffre-maxwell
gov.uscourts.nysd.447706.931.0
15 pg
…we are talking
20 about.
21 MR. MILLER: It is a hundred percent what we are
22 talking about.
23 THE COURT: Okay.
24 MR. MILLER: As I mentioned, they already agreed
25 subject, obviously, your approval, that the deposition
…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.1_1
13 pg
…is received, it shall be the
obligation of the party designating the information as CONFIDENTIAL to file an appropriate
motion requesting that the Court determine whether the disputed information should be
subject to the terms of the Protective Order. If…
giuffre-maxwell
gov.uscourts.nysd.447706.164.0
29 pg
…as here, the
persons asserting the privileges have affirmatively put the subject matter of the materials at issue.
In the most recent of their serial litigations (apart from this case), Plaintiff’s own
attorneys Bradley Edwards (“Edwards) and Paul Cassell…
giuffre-maxwell
gov.uscourts.nysd.447706.1248.0
6 pg
…abuse
victims be disclosed in their entirety, subject only to limited redactions to protect the identity of a
sexual assault victim who has not already been identified as such to the public.
Ms. Giuffre takes no position with regard to…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.50
15 pg
…which her own attorneys have argued (in opposing restrictions on public
access to court filings detailing them) are the subject of “strong current media interest.” Nor
does the fact that Professor Dershowitz is not himself a news agency negate his…
giuffre-maxwell
gov.uscourts.nysd.447706.422.0
8 pg
…s counsel provided that (1) the settlement
agreement is designated as confidential under the protective order; (2) the settlement
agreement is deemed fully subject to the protective order; and (3) the settlement
agreement (including individual terms) will not be publicly…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.37
9 pg
…Here,
Dershowitz easily could have moved for the relief he seeks in his Motion in Limine without
making public the very statements he knows were being challenged as subject to the settlement
5
Case 1:15-cv-07433-LAP…
giuffre-maxwell
gov.uscourts.nysd.447706.1024.0
7 pg
…the right of access to civil
Case 1:15-cv-07433-LAP Document 1024 Filed 01/27/20 Page 5 of 7
complaints attaches only at the moment ‘they become the subject of some type of judicial action.’”
Id…