giuffre-maxwell
gov.uscourts.nysd.447706.858.0
3 pg
…Mr. Cernovich intervention under Rule 24(b).
Accordingly, he is not a party of this litigation, and has no standing to bring the instant
opposition. See Esther Sadowsky Testamentary Trust v. Federal Housing Finance Agency, 412
Fed.Appx. 361, 363…
giuffre-maxwell
gov.uscourts.nysd.447706.992.0
5 pg
…LLP
Page 2
deemed ‘judicial documents,’ requiring the court to balance the public access presumption
against the competing considerations identified by the party seeking to seal them.” Royal Park
Investments SA/NV v. Deutsch Bank Nat’l Trust Co., No…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…behavior that I
abhor and have never ever been party to, witness to events that I have never seen,
living off trust funds that I have never ever had, party to stories that have changed
materially both in time place…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…STATES
VIRGIN ISLANDS, Case No.:
PLAINTIFF,
ACTION FOR DAMAGES
V.
DARREN K. INDYKE, in his capacity as the JURY TRIAL DEMANDED
EXECUTOR FOR THE ESTATE OF JEFFR…
giuffre-maxwell
gov.uscourts.nysd.447706.1312.0
9 pg
…we have to do.”). And “a
generalized concern of adverse publicity concerning a public figure is [not] a sufficiently
compelling reason that outweighs the presumption of access.” Prescient Acquisition Grp., Inc. v.
MJ Public Trust, 487 F. Supp. 2d 374…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…punditry, and analysis.4 As many Americans
continue to lose trust in the purportedly unbiased nature of older newspapers and networks, TGP
highlights that it is addressing this gap as a trusted news source for the stories and views that…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…citing Pansy,
23 F.3d at 782). The Amodeo I court cited two other Third Circuit cases confirming that circuit’s
litmus-test approach to identifying judicial documents: Bank of America National Trust and
Savings Association v. Hotel Rittenhouse Association…
giuffre-maxwell
gov.uscourts.nysd.447706.79.1
12 pg
…certainly subject to comments by plaintiff's counsel
23 and the Court.
24 THE COURT: I am getting to the age where somehow
25 sometimes I don't trust my memory but I thought at our last
SOUTHERN DISTRICT REPORTERS…
giuffre-maxwell
1320-28
32 pg
…behavior that I
abhor and have never ever been party to, witness to events that I have never seen,
living off trust funds that I have never ever had, party to stories that have changed
materially both in time place…
giuffre-maxwell
gov.uscourts.nysd.447706.222.0
10 pg
…1995)). Courts “engage in a balancing test to determine whether
undue burden exists.” Usov, 2014 WL 4354691, *16 (citing Aristocrat Leisure Ltd. v. Deutsche
Bank Trust Co. Americas, 262 F.R.D. 293, 299–300 (S.D.N.Y. 2009…
giuffre-maxwell
gov.uscourts.nysd.447706.551.0
17 pg
…of a democratic society is that the public should know what goes on
in courts”).
Courts have consistently noted that access to courts and court records is important for
public education, public trust, and the integrity of the court system…
giuffre-maxwell
gov.uscourts.nysd.447706.82.0_2
11 pg
…certainly subject to comments by plaintiff's counsel
23 and the Court.
24 THE COURT: I am getting to the age where somehow
25 sometimes I don't trust my memory but I thought at our last
SOUTHERN DISTRICT REPORTERS…
giuffre-maxwell
gov.uscourts.nysd.447706.370.0
17 pg
…17
securities held by Ms. Maxwell or anyone related to her; Id.at RFP 33, 40 and 41.
trust account documents; Id. at RFP 43.
insurance policies held, regardless of whether such policies might cover the claims…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.19
17 pg
…17
securities held by Ms. Maxwell or anyone related to her; Id.at RFP 33, 40 and 41.
trust account documents; Id. at RFP 43.
insurance policies held, regardless of whether such policies might cover the claims…
giuffre-maxwell
gov.uscourts.nysd.447706.702.0
63 pg
…point of the January 2015 statement,
10 was to dissuade the media from republishing plaintiff's false
11 statements. And that's why he made the argument that he did:
12 Do not trust this person, this person tells falsehoods…
giuffre-maxwell
gov.uscourts.nysd.447706.371.2
18 pg
…or held on Your behalf or for Your benefit by another individual or
entity, including trusts from January 2015 to the Present.
RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad
and unduly burdensome…
giuffre-maxwell
gov.uscourts.nysd.447706.436.0
15 pg
…Motors,
307 F.3d 1206 (9th Cir. 2002) ............................................................................................ 3
Prescient Acquisition Grp., Inc. v. MJ Publ’g Trust,
487 F. Supp. 2d 374 (S.D.N.Y. 2007)................................................................................. 5
Rosado v. Brid…
giuffre-maxwell
gov.uscourts.nysd.447706.1253.0
12 pg
…continue specific
to that document.”). And “a generalized concern of adverse publicity concerning a public figure
is [not] a sufficiently compelling reason that outweighs the presumption of access.” Prescient
Acquisition Grp. v. MJ Public Trust, 487 F. Supp. 2d 374…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…stocks, bonds, trusts, and holdings
in businesses (including the business’ tax returns and income statements) far exceed the well-
established practice of providing a net worth statement. A sworn net worth statement is all
Plaintiff needs relevant punitive damages claim…
giuffre-maxwell
gov.uscourts.nysd.447706.1071.0
13 pg
…that counsels in favor of
modification. The thrust of Mr. Dershowitz’s request is that
wholesale production of the Maxwell materials to him will “promote
7
Case 1:15-cv-07433-LAP Document 1071 Filed 07/01/20 Page…
Comments