giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…her lack of credibility, her failures of memory and her selective use of law
enforcement. Regarding the year 2015, the police reports demonstrate Plaintiff’s tumultuous
home life, bearing no relationship to any press statements or alleged defamation and providing…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…wants to
publicize police reports concerning Ms. Giuffre - most of them from when she was a child, some
of them concerning her being raped when only 14 years. Defendant’s challenge to Ms. Giuffre’s
confidentiality designation is without merit…
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…Unsealing Decided Motions, sixteen non-parties
submitted Non-Party Objections in November and December of last year.1 Addressing these Non-
Party Objections now will allow the Court to adjudicate all remaining legal arguments against
unsealing at once, and will…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…wants to
publicize police reports concerning Ms. Giuffre - most of them from when she was a child, some
of them concerning her being raped when only 14 years. Defendant’s challenge to Ms. Giuffre’s
confidentiality designation is without merit…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…a
requirement, however, and in the intervening years courts in this District have presided over
numerous Epstein-related cases and handled sealing (and unsealing) motions without soliciting
objections from third parties who were mentioned in the documents. See, e.g…
giuffre-maxwell
gov.uscourts.nysd.447706.1052.0
4 pg
…a
particular set of documents. That is inconsistent with Paragraph 2(j). And it could take years
before the Court could unseal even the First Five Motions.
Docket Entry 143 and its accompanying briefing, for example, contains approximately 15
Non…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…access to those documents, to which they
have a First Amendment right of access, for years. And if Maxwell’s meritless objections prevail,
the public will never have access to those documents.
Recognizing Plaintiff’s concern, the Court stated in…
giuffre-maxwell
gov.uscourts.nysd.447706.1021.0
18 pg
…6 THE COURT: Here is the deal. We are not doing all
7 the documents at the same time because that would take you 12
8 years to brief and me 12 years to decide.
9 MS. McCAWLEY: Right.
10 …
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…enforceable, witnesses relying upon such orders will be inhibited from giving essential testimony
in civil litigation, thus undermining a procedural system that has been successfully developed
over the years for disposition of civil disputes. 594 F.2d at 295–96…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…rejected these broad subpoenas.
15 Defendants know that they are not entitled to every
16 single personal email plaintiff has ever sent or ever received
17 in the course of however many years these accounts were open.
18 In fact…
giuffre-maxwell
gov.uscourts.nysd.447706.1248.0
6 pg
…fully understand the extent of the allegations – the same allegations that law
enforcement and prosecutors may have been aware of years ago when offering a plea deal to Mr.
Epstein – the accuser’s stories should be disclosed to the public…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…for briefing motions to suppress that begins in January 2021.
Disclosure of witnesses, Rule 404(b) and 415 evidence, Jencks and Giglio material is unlikely to
occur until later next year. Yet, to release this potentially inadmissible evidence publicly now…
giuffre-maxwell
gov.uscourts.nysd.447706.949.0
31 pg
…some of the many squabbles and disputes -- and
20 I emphasize the word "many" -- that the parties had in
21 connection with the discovery in this case.
22 The Court may recall that about two years ago,
23 March 17…
giuffre-maxwell
gov.uscourts.nysd.447706.1351.0
32 pg
…31, 2020).
These parties’ identities were pseudonymized by referring to them on the
public record as “Does,” i.e., “Doe 1,” “Doe 2,” and so on.
Over the next few years, the district court individually reviewed
hundreds of sealed documents…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…allegations in the Sealed Materials may be the
product of false statements, mistake, confusion, or failing memories based upon events
occurring more than sixteen years ago. And, critically, such allegations will never be resolved
here in light of the parties…
giuffre-maxwell
gov.uscourts.nysd.447706.79.2
18 pg
…ence.The C omplaintat
paragraph9 pu rports to d escribe events pertainingto P laintiff and D efend antoccu rringin the
years 1999 –20 0 2.The C omplaintalso references statements attribu ted to M s.M ax well
occu rringin…
giuffre-maxwell
gov.uscourts.nysd.447706.1155.0_2
13 pg
…does not apply to statements made in court filings (like those at
issue here), which should have been unsealed and made public years ago.
J. Does 1 and 2 have not asserted any objections with regard to these materials,
…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.6_1
14 pg
…her lack of credibility, her failures of memory and her selective use of law
enforcement. Regarding the year 2015, the police reports demonstrate Plaintiff’s tumultuous
home life, bearing no relationship to any press statements or alleged defamation and providing…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…172, and 1992 results in a determination that: (a) the
selected Sealed Materials relate solely to five-year-old discovery disputes and therefore, at most,
begin with a presumption of public access “somewhat lower than the presumption applied to
material…
giuffre-maxwell
gov.uscourts.nysd.447706.1010.0
3 pg
…process. At the same time we think it appropriate to point out that
the Court and the parties are effectively doing a substantial amount of work that took
place over a two-year period and encompassed hundreds of court submissions…
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