giuffre-maxwell
gov.uscourts.nysd.447706.981.0
2 pg
…Intervenor Michael Cernovich d/b/a Cernovich Media originally sought to intervene and
unseal the wholly-redacted summary judgment documents filed by Defendant Ghislaine
Maxwell and the subsequent summary judgment documents that would be filed relative
to Maxwell’s motion…
giuffre-maxwell
gov.uscourts.nysd.447706.1034.0
16 pg
…1026.) The Court
disagrees. Because a subsequent naming of a non-party in the
sealed materials may carry a different context from the naming
of that non-party in the unsealed materials, the unsealing
may present different consequences for the…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…trial. Ms. Maxwell’s responses to Plaintiff’s Interrogatories
are based on information currently known to her and are given without waiving Ms. Maxwell’s
right to use evidence of any subsequently discovered or identified facts, documents or
communications. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1059.0
3 pg
…. . prior rulings in subsequent stages of
the same case absent cogent and compelling reasons such as an intervening change of
controlling law, the availability of new evidence, or the need to correct a clear error or prevent
manifest injustice.” United…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.7
11 pg
…the motion
12 to strike the testimony that you allowed over the
13 ruling.
14 SPECIAL MASTER: And there's a series of
15 those things that might need to be cleaned up in a
16 subsequent sitting.
17 MR…
giuffre-maxwell
gov.uscourts.nysd.447706.833.0
4 pg
…itself. Such argument occurred in open
court, with counsel for Movant present throughout the entirety of the arguments, as well as the
subsequent conference regarding case logistics. Notably, immediately prior to the beginning of
his argument on summary judgment, counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…has
reviewed confidential and sealed materials from Maxwell, the Court subsequently directed the
parties in Dershowitz to confer regarding “reasonable accommodation concerning Mr.
Dershowitz’s requests for various filings and discovery materials from Giuffre v. Maxwell” so as
to be …
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…case.
3. Ransome responds to the requests as she reasonably interprets and understands the
requests. Should Defendant subsequently assert an interpretation of any individual request that
differs from her understanding, she reserves the right to supplement the responses.
4. To…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…case.
3. Ransome responds to the requests as she reasonably interprets and understands the
requests. Should Defendant subsequently assert an interpretation of any individual request that
differs from her understanding, she reserves the right to supplement the responses.
4. To…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…case.
3. Ransome responds to the requests as she reasonably interprets and understands the
requests. Should Defendant subsequently assert an interpretation of any individual request that
differs from her understanding, she reserves the right to supplement the responses.
4. To…
giuffre-maxwell
gov.uscourts.nysd.447706.1187.0
3 pg
…the parties unrestricted authority to disclose
publicly the confidential materials from Maxwell--not least of
all because the parties only may agree to downgrade
confidentiality designations for materials that the “designating
party has subsequently produced in this action,” i.e.…
giuffre-maxwell
gov.uscourts.nysd.447706.26.1
26 pg
…had publicly
defamed her in statements made by individuals operating
at his direction or within scope of their employment. Cases that cite this headnote
Complaint was subsequently amended to include similar
claims by two additional plaintiffs. Defendant moved to
dismiss.
…
giuffre-maxwell
gov.uscourts.nysd.447706.371.2
18 pg
…trial. Ms. Maxwell’s responses to Plaintiff’s requests are
based on information currently known to her and are given without waiving Ms. Maxwell’s right
to use evidence of any subsequently discovered or identified facts, documents or
communications. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.88.0
7 pg
…of
Florida. In pleadings filed in that action, Mr. Edwards made representations on behalf of the
Plaintiff here that were stricken by the Court as “immaterial and impertinent.” These statements
were publicized and subsequently denied by Ms. Maxwell. Thereafter, Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…specifically filed in the CVRA case
to oppose his efforts to intervene in that case and was unquestionably already in his possession.
Plaintiffs subsequently delivered a Bates stamped version of their original July 2015
document production to Dershowitz's counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.13
22 pg
…place where they are located.” (cleaned up)).
C. The government’s subpoena to was an unconstitutional
Fourth Amendment seizure.
Although Fourth Amendment challenges typically involve “the subsequent search of the
container rather than to its initial seizure by the authorities, …
giuffre-maxwell
gov.uscourts.nysd.447706.1353.0
6 pg
…Mar. 25, 2021).
3
There is no basis to believe that the protective order or subsequent sealing of documents were
imposed solely for Maxwell’s benefit; Judge McMahon discussed “Maxwell[’s] … degree of pro-
tection” because she “assume[d]…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.38
8 pg
…Mr. Dershowitz by requiring him to pay Ms. Giuffre's attorneys' fees relating to sealing
Mr. Dershowitz's affidavit and the subsequent work and motion practice related to his continuing
violations of thi s Court's Order. See, e.g.…
giuffre-maxwell
gov.uscourts.nysd.447706.41.5
18 pg
…No bullets or numbering, Tab stops: 1",
Formatted: Font: 12 pt
failure to do so shall not preclude a subsequent challenge thereto. Moreover,
…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…court. It holds “that when a court has ruled on an issue, that
decision should generally be adhered to by that court in subsequent stages in the
same case,” unless “cogent” and “compelling” reasons militate otherwise.
United States v. Quintieri…
Comments