DataSet-9
EFTA00209236
20 pg
…asked the
Court to enter:
a Protective Confidentially Order which (1) limits the dissemination of certain
Confidential Discovery Material ("CDM") described below, to a designated list of
the Plaintiffs' counsel and support staff, and (2) prohibits any party from filing
…
DataSet-9
EFTA00086283
7 pg
…documents maintained in the files of the USAO-SDNY, conversations with members
of the Noel and Tartaglione prosecution teams at the USAO-SDNY, public court filings, and
conclusions made in accordance therewith.
EFTA000…
DataSet-9
EFTA00801646
19 pg
…Edwards, Cassell and Dershowitz resolved their respective claims and
Edwards and Cassell informed the Court that the filing of their action against Dershowitz was a
"tactical mistake." (Dershowitz, Notice of Withdrawal of Motion for Partial Summary Judgment.)
In order to…
DataSet-9
EFTA00085098
18 pg
…and incorporated
unseal the entire docket. The District Court exhibits; and (2) court filings made in the
granted each of these motions to intervene, course of the discovery process and with
but denied the related requests to unseal in respect…
giuffre-maxwell
gov.uscourts.nysd.447706.1155.0_2
13 pg
…with specificity the testimony she believes should be sealed.
Local Criminal Rule 23.1 applies to extrajudicial statements that go beyond the
public record—it does not apply to statements made in court filings (like those at
issue here)…
DataSet-9
EFTA00039908
55 pg
…documents maintained in the
files of the USAO-SDNY, conversations with members of the Noel and Tartaglione prosecution
teams at the USAO-SDNY, public court filings, and conclusions made in accordance therewith.
3. I submit this declaration in support of…
DataSet-9
EFTA00099647
7 pg
…conversations with members
of the Noel and Tartaglione prosecution teams at the USAO-SDNY, public court filings, and
conclusions made in accordance therewith.
EFTA00099647
Case 1:20-cv-00833-PAE Document …
DataSet-9
EFTA00039895
13 pg
…documents maintained in the
files of the USAO-SDNY, conversations with members of the Noel and Tartaglione prosecution
teams at the USAO-SDNY, public court filings, and conclusions made in accordance therewith.
3. I submit this declaration in support of…
DataSet-9
EFTA00088654
7 pg
…conversations with members
of the Noel and Tartaglione prosecution teams at the USAO-SDNY, public court filings, and
conclusions made in accordance therewith.
EFTA00088654
Case 1:20-cv-00833-PAE Document …
DataSet-9
EFTA00805407
21 pg
…ongoing investigation, the Miami Herald has sought to access public
court filings that will shed light on the scope of Epstein's crimes and address serious questions
about whether there was any undue influence that tainted the investigation. These include…
DataSet-9
EFTA00075477
74 pg
…Maxwell's objection, Judge Preska —who is presiding
over the civil case and the litigation about the unsealing of the district court
filings —ordered the complete unsealing of Ms. Maxwell's April 2016 deposition
transcript and Doe 1's deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…upon by the court. In fact, Brown provided a cautionary
12
Case 1:15-cv-07433-LAP Document 1068 Filed 06/24/20 Page 17 of 24
note that the public should recognize that public court filings do not…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…Maxwell requests the Court enforce the Protective Order, deny
Plaintiff’s motion to make publicly available police reports “Confidential” under the terms of the
Protective Order in this case, and award attorneys’ fees and costs associated with the filing of
…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…foregoing
document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing
document is being served to all parties of record via transmission of the Electronic Court Filing
System generated by CM/ECF…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…underage girls. The Court is also aware that, as things stand today, all of this testimony is under
3
Id. Ms. Giuffre will be filing an opposition to Dershowitz’s motion to intervene shortly.
4
See McCawley Decl. at Composite…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.6_1
14 pg
…Maxwell requests the Court enforce the Protective Order, deny
Plaintiff’s motion to make publicly available police reports “Confidential” under the terms of the
Protective Order in this case, and award attorneys’ fees and costs associated with the filing of
…
DataSet-9
EFTA00075024
31 pg
…how each
document was an abuse of court records, merely stating that the documents are "textbook examples
of materials that should not be submitted to courts because of their potential for abuse." Id. Filing
excerpts from deposition transcripts or summaries…
giuffre-maxwell
gov.uscourts.nysd.447706.1025.0
17 pg
…were presumptuous about the Court’s
resources and inclinations. Doe’s protocol contemplated that each objecting non-party
would submit requests for excerpts and objections “under seal” and would file
“a redacted objection” on the Electronic Case Filing system “reflecting…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.0
16 pg
…are advised in their Objection to Un-Sealing at ¶ 2 that they
“understand this Objection will be filed under seal and I will not be identified in any court
filing.” Ms. Maxwell remains concerned that Non-Parties will be reluctant…
DataSet-9
EFTA00091006
7 pg
…reply filing, the Government respectfully requests leave to reply to those examples or
arguments.
EFTA00091010
The Honorable Alison J. Nathan
July 28, 2020
Page 6
Government.4 The defendant cites not a single example in any district court in…