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on in ordering the unsealing of the deposition materials and that Maxwell's interests outweighed the public's interests in access to the materials. Giuffre v. Maxwell, No. 20-2413 (2d Cir.), (Dkt. No. 140-1 at 2). On October 19, 2020, the Second Circuit found that Judge Preska "correctly held that the deposition m
on a motion to dismiss without the benefit of the full factual record. The motion should be denied. allegations that were central to the dispute in Giuffre v. Maxwell." (Def. Mot. 4, Ex. I at 7:3-6.) (The last colloquy has been unsealed except for Minor Victim-2's name. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1).)
"the rule that `an indictment need do little more than to track the language of the statute charged,'" her motion should be denied. United States v. Murgio, 209 F. Supp. 3d 698, 716 (S.D.N.Y. 2016) (Nathan, J.) (quoting Stringer, 730 F.3d at 124). First, the use of pseudonyms to refer to minor victims
d 91, 99 (2d Cir. 2001). "This standard is an exacting one, and only rarely is alleged surplusage stricken from an indictment." 159 EFTA00077791 Murgio, 209 F. Supp. 3d at 724 (internal quotation marks omitted) (quoting United States v. Smith, 985 F. Supp. 2d 547, 610 (S.D.N.Y. 2014)). In setting f
on in ordering the unsealing of the deposition materials and that Maxwell's interests outweighed the public's interests in access to the materials. Giuffre v. Maxwell, No. 20-2413 (2d Cir.), (Dkt. No. 140-1 at 2). On October 19, 2020, the Second Circuit found that Judge Preska "correctly held that the deposition m
on a motion to dismiss without the benefit of the full factual record. The motion should be denied. allegations that were central to the dispute in Giuffre v. Maxwell." (Def. Mot. 4, Ex. I at 7:3-6.) (The last colloquy has been unsealed except for Minor Victim-2's name. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1).)
"the rule that `an indictment need do little more than to track the language of the statute charged,'" her motion should be denied. United States v. Murgio, 209 F. Supp. 3d 698, 716 (S.D.N.Y. 2016) (Nathan, J.) (quoting Stringer, 730 F.3d at 124). First, the use of pseudonyms to refer to minor victims
d 91, 99 (2d Cir. 2001). "This standard is an exacting one, and only rarely is alleged surplusage stricken from an indictment." 159 EFTA00039606 Murgio, 209 F. Supp. 3d at 724 (internal quotation marks omitted) (quoting United States v. Smith, 985 F. Supp. 2d 547, 610 (S.D.N.Y. 2014)). In setting f
ess attaches, and did not abuse its discretion in rejecting Maxwell's meritless arguments that her interests superseded the presumption of access." Giuffre v. Maxwell, No. 20-2413 (2d Cir.) (Dkt. No. 140-1 at 3).43 On October 22, 2020, the defendant's April 2016 deposition was publicly filed. (See 15 Civ. 7433 (L
Count Six, stating that the "testimony is .. . far afield from the sex trafficking and sexual abuse allegations that were central to the dispute in Giuffre v. Maxwell." (Def. Mot. 4, Ex. I at 7:3-6.) (The last colloquy has been unsealed except for Minor Victim-2's name. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1).)
"the rule that `an indictment need do little more than to track the language of the statute charged,' her motion should be denied. United States v. Murgio, 209 F. Supp. 3d 698, 716 (S.D.N.Y. 2016) (Nathan, J.) (quoting Stringer, 730 F.3d at 124). 152 EFTA00095244 First, the use of pseudonyms to ref
the relevance of these allegations, the defendant has not satisfied the "exacting" standard required to justify striking portions of an Indictment. Murgio, 209 F. Supp. 3d at 724 (quoting Smith, 985 F. Supp. 2d at 610). Accordingly, the motion should be denied, or, 57 The defense motion takes issue wi
as aware, Doe v. Indyke was the "lone case in this District that has not yet been either resolved or stayed at this point. . . In 23 In particular, Giuffre v. Maxwell was resolved in 2017 and the determination of what material should remain sealed remains the only open issue. Accordingly, there is no more discover
by a stay in the Doe case because the outcome of the criminal case could resolve disputed issues in the Doe case. Such concerns are not present in Giuffre v. Maxwell. 57 EFTA00077689 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine M
7, 262 United States v. Mulder, 273 F.3d 91 (2d Cir. 2001) 241, 242 United States v. Mullens, 536 F.2d 997 (2d Cir. 1976) 139 United States v. Murgio, 209 F. Supp. 3d 698 (S.D.N.Y. 2016) 231, 241, 247 United States v. Muric, No. 10 Cr. 112 (LTS), 2010 WL 2891178 (S.D.N.Y. July 13, 2010) 86 Un
as aware, Doe v. Indyke was the "lone case in this District that has not yet been either resolved or stayed at this point. . . In 23 In particular, Giuffre v. Maxwell was resolved in 2017 and the determination of what material should remain sealed remains the only open issue. Accordingly, there is no more discover
by a stay in the Doe case because the outcome of the criminal case could resolve disputed issues in the Doe case. Such concerns are not present in Giuffre v. Maxwell. 57 EFTA00039504 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine M
7, 262 United States v. Mulder, 273 F.3d 91 (2d Cir. 2001) 241, 242 United States v. Mullens, 536 F.2d 997 (2d Cir. 1976) 139 United States v. Murgio, 209 F. Supp. 3d 698 (S.D.N.Y. 2016) 231, 241, 247 United States v. Muric, No. 10 Cr. 112 (LTS), 2010 WL 2891178 (S.D.N.Y. July 13, 2010) 86 Un
stayed at this point. . . In particular, this matter appears to be the only remaining active civil case in this District in which 23 In particular, Giuffre v. Maxwell was resolved in 2017 and the determination of what material should remain sealed remains the only open issue. Accordingly, there is no more discover
by a stay in the Doe case because the outcome of the criminal case could resolve disputed issues in the Doe case. Such concerns are not present in Giuffre v. Maxwell. 57 EFTA00095149 claims against Ghislaine Maxwell have been asserted." (20 Civ. 484 (DCF) (JGK), Dkt. No. 80 at 2). The defendant's baseless con
60, 163, 171 United States v. Mulder, 273 F.3d 91 (2d Cir. 2001) 159 United States v. Mullens, 536 F.2d 997 (2d Cir. 1976) 97 United States v. Murgio, 209 F. Supp. 3d 698 (S.D.N.Y. 2016) 152, 159, 162 United States v. Muric, No. 10 Cr. 112 (LTS), 2010 WL 2891178 (S.D.N.Y. July 13, 2010) 59 Un
Entities connected to both Giuffre v. Maxwell and Murgio

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSONthe Southern District
LOCATION
United States
LOCATION
Virginia Giuffre
PERSON
Bradley Edwards
PERSON
Julie K. Brown
PERSONJane Doe
PERSONSweet
PERSON
Bill Richardson
PERSONMaria Farmer
PERSON
David Boies
PERSON
George Mitchell
PERSONthe Second Circuit's
ORGANIZATION
Scarlett Johansson
PERSON
Supreme Court
ORGANIZATION
Anderson
PERSON
Rivera
PERSON
Kaplan
PERSONStokes
PERSON