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.447706.1122.0_2
13 pg
…in support of its motion to intervene (Doc. 1110) in this action for the limited
purpose of obtaining confidential access to both: (a) all still-sealed documents related to the
parties’ motions for summary judgment [ECF No. 540 to 543…
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.447706.1073.0
22 pg
…to non-dispositive motions… ‘is generally 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.’”) (quoting Brown, 929
F.3d at 50).
A…
giuffre-maxwell
gov.uscourts.nysd.447706.604.0
11 pg
…and personal vendettas. Plaintiff’s arguments are
unsupported by law or fact.
One week after Cernovich sought to intervene and unseal the summary judgment
pleadings, counsel for Plaintiff filed yet another action in this District against Defendant
Ghislaine Maxwell (“Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.811.0
2 pg
…consists of him simply reading portions of those briefs aloud”. If this is the case,
then it is even more apparent there is no basis for sealing the summary judgment
pleadings, let alone the transcript.
Undersigned counsel was present at…
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.447706.898.0
4 pg
…weeks, the practice of filing nearly all substantive submissions under seal has not
abated, and the Court just yesterday denied a motion to unseal the papers filed in connection with
the Defendant’s summary judgment motion. See ECF No. 892…
giuffre-maxwell
gov.uscourts.nysd.447706.941.0
6 pg
…not authorize the Court to dispense with the letter request as this entire
action was not placed under seal.
Thus, on January 19, 2017, after the defendant filed an overly-redacted motion for
summary judgment (Dkt. Nos. 540-542), Mr…
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…
giuffre-maxwell
gov.uscourts.nysd.447706.892.0
11 pg
…to
modify the protective order entered in this action in order to
unseal particular documents submitted in connection with the
motion of defendant Ghislaine Maxwell (" Maxwell " or the
"Defendant") for summary judgment to dismiss the complaint of
plaintiff Virginia L …
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…19, 2019) (listing
in a cursory fashion several reasons that the summary judgment materials should remain under in
response to the Second Circuit’s order to show cause). Her consistent failure to adhere to the
3
Case 1:15…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.17
13 pg
…Ms. Maxwell’s summary judgment brief, her attorney’s declaration in support of the summary
judgment motion, and any “pleadings, memoranda, declarations, exhibits, orders, and other
documents filed or to be filed” in connection with the summary judgment motion. Doc…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…Prime Minister, and other world leaders,’ as well as Dershowitz (a long-time member of the
1
Curiously, he died the very day after this Court’s summary judgment record was unsealed by the
Second Circuit.
2
Reinstein, Julia, 23…
giuffre-maxwell
gov.uscourts.nysd.447706.89.0
10 pg
…of the Jane Doe 1 and
Jane Doe 2, Professor Cassell and Bradley Edwards recently filed a 60-page summary judgment
motion (DE #361). As that summary judgment motion makes clear, the claims raised in that case
concern whether the…
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…sealed documents filed in support of
Defendant Ghislaine Maxwell’s motion for summary judgment
(dkt. nos. 540-43);
• All currently sealed documents filed in support of
Plaintiff Virginia L. Giuffre’s opposition to Defendant’s
motion for summary judgment (dkt…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…to intervene is granted, and the motion to
unseal is denied as to the documents produced in the discovery
process and as to the summary judgment judicial documents based
on the difficult balancing of the conflicting principles
described below.
I. …
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…this action, the trial will be bifurcated. . . . Therefore, defendant's motions for
partial summary judgment and to stay discovery as to his financial status are
denied.
Tillery v. Lynn, 607 F. Supp. 399, 402-03 (S.D.N.Y. 1985…
giuffre-maxwell
gov.uscourts.nysd.447706.406.0
31 pg
…II, 71 F.3d at 1049. This is
not a situation where the documents were relied upon as part of a dispositive summary judgment
motion (where the presumption is highest). If the Court relied on the documents at all, which…