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Extracted Text (OCR)
Case 1:15-cv-07433-LAP Document 1332-17 Filed 01/08/24 Page 9 of 13
[T]wo appeals involving this case (and to which Ms. Giuffre has been named as a
party) are currently pending in the Second Circuit. These two appeals [by Messrs.
Dershowitz and Cernovich] involve some of the confidential documents that you
are, apparently, proposing may need to be destroyed now.
Until those appeals have been resolved, it would be premature to begin
implementing paragraph 12’s provision.
EXHIBIT B.
On September 6, 2018, we renewed our request that Ms. Giuffre and her counsel comply
with Paragraph 12 “in light of Judge Sweet’s Opinions of November 14, 2017 [denying
Mr. Epstein and Ms. Groff’s motion to unseal] and August 27, 2018 [denying the Miami
Herald’s motion to unseal]. EXHIBIT C. Ms. Giuffre’s counsel again rejected our request.
Mr. Cassell repeated that this case had not concluded. In addition to the two pending appeals
involving Messrs. Dershowitz and Cernovich, he said, the Miami Herald’s appeal of the denial of
its motion to unseal also was pending. “Until the three pending appeals have been resolved,” he
concluded, “it continues to be the case that it would be premature to begin implementing
paragraph 12’s provisions.” EXHIBIT D. Mr. Cassell did not address this Court’s conclusion in its
November 14, 2017, opinion that this case terminated on May 25, 2017, and as of that date the
parties were required to comply with Paragraph 12.
On November 21, 2018, we conferred once more with Ms. Giuffre’s counsel. They said
their position remained unchanged.
Ms. Giuffre’s and her counsel’s position violates the Protective Order. Their position that
this case has not concluded flies in the face of this Court’s conclusion and direction to the parties
more than a year ago to comply with Paragraph 12. In its sealed Opinion issued November 14,
2017, the Court ruled that this lawsuit concluded for purposes of Paragraph 12 on May 25, 2017,
Extracted Information
Document Details
| Filename | Giuffre_Maxwell_Batch7_p00324.png |
| File Size | 292.4 KB |
| OCR Confidence | 95.2% |
| Has Readable Text | Yes |
| Text Length | 1,954 characters |
| Indexed | 2026-02-04 12:48:42.958935 |