giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…11, 2016
Declaration.
Introduction and Overview
2. Rather than offering a valid and proper basis for opposing my motion, the
papers submitted on behalf of plaintiff Virginia Roberts Giuffre—particularly, the lengthy
declaration of Paul Cassell, one of Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
…11, 2016
Declaration.
Introduction and Overview
2. Rather than offering a valid and proper basis for opposing my motion, the
papers submitted on behalf of plaintiff Virginia Roberts Giuffre—particularly, the lengthy
declaration of Paul Cassell, one of Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…2018, and
entered in this action on August 27, 2018.
Dated: September 26, 2018
New York, New York
Respectfully submitted,
/s/ Christine N. Walz
Sanford L. Bohrer…
giuffre-maxwell
gov.uscourts.nysd.447706.113.0
3 pg
…v. Maxwell,
Case no. 15-cv-07433-RWS – Regarding Pro Hac Vice Motion of Bradley J.
Edwards
Dear Judge Sweet:
This letter is in response to the Court’s direction that additional material be submitted
regarding Bradley J. Edwards, Esq…
giuffre-maxwell
gov.uscourts.nysd.447706.944.0
11 pg
…a case that was
resolved more than a year ago. And it seeks post facto to examine a relatively few sealed and
redacted documents submitted among more than 900 court filings. That is only the beginning of
the extraordinary nature…
giuffre-maxwell
gov.uscourts.nysd.447706.435.0
27 pg
…11, 2016
Declaration.
Introduction and Overview
2. Rather than offering a valid and proper basis for opposing my motion, the
papers submitted on behalf of plaintiff Virginia Roberts Giuffre—particularly, the lengthy
declaration of Paul Cassell, one of Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1253.0
12 pg
…Virginia Giuffre
files this Reply to Non-Parties 28, 97 and 144’s Objections to unsealing.
PRELIMINARY STATEMENT
Does 12, 28, 97, and 144 have submitted replies in response to Plaintiff’s March 18, 2022
brief. Dkt. 1247. Does 147…
giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…judicial machinery as an expansive civil grand jury to extract and coerce
witnesses to reveal private, sensitive and confidential information. Having acquired the
information and having gratuitously submitted much of the information in sealed court
submissions, Ms. Giuffre changed course…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…Page 2 of 6
Page 2 of 6
Doe’s letter in opposition to the Joint Letter submitted to the Court by the parties in
Dershowitz rehashes the arguments he has made previously regarding the unsealing of documents
in Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1258.0
3 pg
…opposition papers, if any, shall be served in accordance with
Local Civil Rule 6.1.
Dated: July 28, 2022. Respectfully Submitted,
/s/ Marc J. Randazza
Marc Randazza, (Pro Hac Vice forthcoming)
…
giuffre-maxwell
gov.uscourts.nysd.447706.1071.0
13 pg
…15-cv-07433-LAP Document 1071 Filed 07/01/20 Page 2 of 13
(S.D.N.Y.), and Maxwell submitted a number of letters in response
to Mr. Dershowitz’s request and participated in oral argument on
June 23…
giuffre-maxwell
gov.uscourts.nysd.447706.1264.0
1 pg
…the parties, and non-parties have endeavored to
adhere.
Accordingly, TGP’s request to intervene and unseal should be denied.
Respectfully Submitted,
KRIEGER KIM & LEWIN LLP
By:…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.2
13 pg
…lining," "linty," etc.
Accordingly, the below search terms are submitted with wildcard characters to be applied
in the manner of the examples above. Please apply them as such with whatever characters is
required by the software/platform that you will…
giuffre-maxwell
gov.uscourts.nysd.447706.1242.0
9 pg
…55, and 56’s Objections to unsealing docket entries containing
references to them.
PRELIMINARY STATEMENT
Only Non-Party Does 54, 55, and 56 have submitted reply submissions in response to
Plaintiff’s opening brief filed on January 12, 2022. Dkt…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.17
13 pg
… 12. The parties
produced thousands of pages of Confidential Materials under the Protective Order.
The parties submitted various Confidential Materials under seal as exhibits to court
filings. The Protective Order provided that any such materials submitted to the Court “shall…
giuffre-maxwell
gov.uscourts.nysd.447706.1284.0
17 pg
…connection with a decided
6 motion or papers that are relevant to the Court's exercise of
7 its inherent supervisory powers.
8 The documents at issue here were submitted in
9 connection with discovery motions decided by Judge Sweet…
giuffre-maxwell
gov.uscourts.nysd.447706.1283.0
17 pg
…connection with a decided
6 motion or papers that are relevant to the Court's exercise of
7 its inherent supervisory powers.
8 The documents at issue here were submitted in
9 connection with discovery motions decided by Judge Sweet…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…2015, Ms. Giuffre submitted her first set of Requests for Production.
Defendant failed to make a reasonable search or production of her documents, and Ms. Giuffre
sought relief from the Court numerous times:
1
Plaintiff’s Response in…
giuffre-maxwell
gov.uscourts.nysd.447706.1135.0_6
1 pg
…Ms. Maxwell is submitting any proposed
redactions to the materials to be unsealed tomorrow morning that are in conflict with
Plaintiff’s proposed redactions. These redactions all relate to “descriptions of nonparty
conduct that would allow readers to discern the…
giuffre-maxwell
gov.uscourts.nysd.447706.1067.0
10 pg
…attaches to all judicial documents.
Maxwell’s repeated assertion that these documents are entitled to “a minimal presumption of
access” is directly contradicted by the Second Circuit’s conclusion that “the presumption of access
to “materials submitted in connection with…