giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…The Government of the United States Virgin Islands (the “USVI”) moves to intervene in
this action for the limited purpose of obtaining confidential access to both: (a) all sealed
documents related to the parties’ motions for summary judgment [ECF No…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…with respect to both of claims against the Defendant, Alan Dershowitz, and (2) final
summary judgment as to Dershowitz's First Amended Counterclaim against them, and in support
thereof state as follows:
I. INTRODUCTION
As the Court is well aware…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.19
12 pg
…on
the ground of attorney-client privilege because those, too, were waived by Defendant’s approval
to submit Mr. Barden’s self-serving declaration in support of Summary Judgment. Specifically,
Ms. Giuffre, hereby moves this Court to Order Defendant to…
giuffre-maxwell
gov.uscourts.nysd.447706.610.0
3 pg
…ARGUMENT
Intervenor Alan M. Dershowitz1 hereby joins in the pending motion by Michael
Cernovich d/b/a Cernovich Media (“Cernovich”) to unseal all papers filed under seal in relation
to Defendant’s pending motion for summary judgment. Dershowitz relies upon…
giuffre-maxwell
gov.uscourts.nysd.447706.978.0
27 pg
…2018 are VACATED. The
Court further ORDERS the unsealing of the summary judgment record as described in its
opinion. The case is REMANDED to the District Court for a particularized review of the
remaining materials.
For the Court:
…
giuffre-maxwell
gov.uscourts.nysd.447706.977.0
27 pg
…2018 are VACATED. The
Court further ORDERS the unsealing of the summary judgment record as described in its
opinion. The case is REMANDED to the District Court for a particularized review of the
remaining materials.
For the Court:
…
giuffre-maxwell
gov.uscourts.nysd.447706.165.0
4 pg
…and correct copy of the Order in the CVRA Case
dated April 6, 2015.
6. Attached as Exhibit E is a true and correct copy of the Motion for Summary
Judgment in the Edwards and Cassell v. Dershowitz, Case No…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.27
11 pg
…2016.
On January 6, 2017, Mr. Barden submitted a declaration in support of Ms. Maxwell’s
motion for summary judgment. In the declaration, he stated, “I am not authorised to and do not
waive Ms. Maxwell’s attorney-client privilege…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…just reached agreement.
Shortly before 5 p.m. today, Edwards and Cassell moved to withdraw their motion for partial
summary judgment. Their moving papers acknowledge a confidential settlement and mutual
release between themselves and Dershowitz, then go on to state:
…
giuffre-maxwell
gov.uscourts.nysd.447706.1060.0
2 pg
…the Second Circuit unsealed the summary judgment motion and
ordered particularized review of the remaining materials for the purpose of unsealing. Maxwell,
929 F.3d at 44-45. As this Court well knows, the summary judgment briefing contained many of…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.11
5 pg
…12 (filed under seal).
14. Attached hereto as Exhibit 12 is a true and correct copy of Notice of Withdrawal of
Summary Judgment Motion.
15. Attached hereto as Exhibit 13 is a true and correct copy of Affidavit of Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.185.0
5 pg
… Attached hereto as Exhibit 12 is a true and correct copy of Notice of Withdrawal of
Summary Judgment Motion.
15.
Case 1:15-cv-07433-LAP Document 185 Filed 06/01/16 Page 3 of 5
16.
17.
18…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…May 3, 2017,
and August 27, 2018, ORDER the unsealing of the summary judgment
record as described further herein, and REMAND the cause to the
District Court for particularized review of the remaining sealed
materials.
I. BACKGROUND
A. Jeffrey Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1097.0_1
6 pg
…Relatedly, the parties request that the Court clarify that
deposition transcripts and other documents not designated
confidential on their face (excerpts of some of which were
submitted under seal as part of the (now unsealed) summary judgment
record in Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…and therefore, at most,
begin with a presumption of public access “somewhat lower than the presumption applied to
material introduced at trial, or in connection with dispositive motions such as motions for
dismissal or summary judgment.” Brown v. Maxwell, 929…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…May 3, 2017,
and August 27, 2018, ORDER the unsealing of the summary judgment
record as described further herein, and REMAND the cause to the
District Court for particularized review of the remaining sealed
materials.
I. BACKGROUND
A. Jeffrey Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.589.0
24 pg
…Materials that are Appropriate for a Protective Order .........................................9
D. Cernovich’s Attempt to Make a Distinction About Summary Judgment
Materials Also Fails ...............................................................................................10…
giuffre-maxwell
gov.uscourts.nysd.447706.967.0
7 pg
…In January 2017 , Intervenor
Michael Cernovich ("Cernovich " ) requested unsealing of Maxwell's
summary judgment brief, her attorney's declaration in support of
the summary judgment motion, and any documents filed in
connection with the summary judgment motion. See ECF No…
giuffre-maxwell
gov.uscourts.nysd.447706.899.0
1 pg
…892), Intervenor is particularly concerned
that the Court did not unseal any portion of the statement of facts and that it unsealed
no portion of the memoranda by the parties in support or in opposition to summary
judgment. As the…
giuffre-maxwell
gov.uscourts.nysd.447706.1118.0
21 pg
…course, a party to this closed civil defamation
case. The Government seeks two categories of documents: 1) summary judgment materials that
are already publicly available due to their release on the Second Circuit Court’s docket on
August 9, 2019…