giuffre-maxwell
gov.uscourts.nysd.447706.1206.13
22 pg
…3. The government could have been, but was not, more
targeted in its approach. The government has not provided Maxwell with a copy of the subpoena,
but the record shows that the subpoena was incredibly broad and, as explained below…
giuffre-maxwell
gov.uscourts.nysd.447706.1196.0
32 pg
…be unsealed and docketed in the form that they were
8 received from the law enforcement agency. This is also
9 consistent with the approach that the Court of Appeals has
10 taken. Consistent with the Court of Appeals' approach…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
… And CW then contacts the
18 FBI; and the FBI sets up a sting operation to indict
19 Mr. Rodriguez.
20 If I can approach, your Honor, I'd like to talk a
21 little bit about the affidavit that…
giuffre-maxwell
gov.uscourts.nysd.447706.1105.0
8 pg
…participation.
And, indeed, precedent mandates the protocol’s approach: “[t]he job of protecting [non-
party privacy rights] rests heavily upon the shoulders of the trial judge.” In re New York Times
Co., 828 F.2d 110, 116 (2d Cir…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.22
40 pg
…8 Q. And how did you meet her?
9 A. She approached me while I was on campus at
10 Palm Beach Atlantic College.
11 Q. And what happened when she approached you?
12 A. She asked me if I…
giuffre-maxwell
gov.uscourts.nysd.447706.1071.0
13 pg
…of the discovery from Maxwell,”” he has not
beyond conclusory assertions demonstrated a congruence between the
Maxwell action and his own that would warrant such an
indiscriminate approach.
A brief comparison of the Maxwell and Dershowitz actions makes
this clear…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…proffer as to how
the question was within the Court’s Order, the question was withdrawn and a different question
was posed: “Mr. Boies: Let me approach it this way.” … Did Ms. Ward tell you that?” The
questioning about …
giuffre-maxwell
gov.uscourts.nysd.447706.1099.0
4 pg
…Maxwell’s deposition or Doe 1’s deposition,
regardless of whether those motions mention Doe 1 or Doe 2. Plaintiff disagrees with this
approach, as the parties agreed and the Court ordered that the Protocol would proceed by Non-
Party…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.22_1
12 pg
…As she is trying to explain, and
11 I'm asking questions because I'm as feared as
12 she is at this point. We hear people
13 approach and she just shuts up.
14 Q. What happens next?
15 …
giuffre-maxwell
gov.uscourts.nysd.447706.1242.0
9 pg
…should do so by only redacting these Does’ names. Dkt. 1237
at 10. Does 55 and 56 reject that approach; instead, they argue that the sealing of their names
would be insufficient to anonymize them. Does 55 & 56 Reply Objs…
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
…7 Thank you.
8 MS. McCAWLEY: Good morning, your Honor. May I
9 approach with a bench book?
10 THE COURT: Sure.
11 MS. McCAWLEY: Thank you.
12 THE COURT: I think in duplicate. Do you have another
13 copy…
giuffre-maxwell
gov.uscourts.nysd.447706.587.0_2
10 pg
…so
20 that I don't have to say it out loud. It is certain pieces
21 that we have already provided that have been attached to our
22 filings but in summary form.
23 If I can approach?
24 …
giuffre-maxwell
gov.uscourts.nysd.447706.1335.3
223 pg
…four hours in my mind is
13 not a hard and fast four hours based upon how we
14 proceed in this deposition. So I'll take that
15 into consideration as we approach the four hours.
16 A. Yes…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…they're specifically talking
20 about here.
21 THE COURT: Thank you very much. I will reserve
22 decision.
23 The motion to quash the Epstein --
24 MR. POE: May I approach the podium, your Honor?
25 THE COURT: Yes…
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…employee, (ii) Epstein affiliate, (iii) victim, etc.) so that they can be addressed in groups.
Such an approach, however, would delay speeding up the process until after her criminal
proceedings,3 and will only to lead to more disputes. Even…
giuffre-maxwell
gov.uscourts.nysd.447706.1062.0
7 pg
…not oppose Dershowitz’s motion is of no moment. Indeed, it proves the point,
by underscoring the caution with which the Court should approach Dershowitz’s request. And,
in any event, a non-party that produces information in discovery remains…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…with
During a sworn taped statement, stated she met
Jeffrey Epstein through Haley Robson. Robson would approach females
who wished to work for him. ••■■~ stated she was asked to.work for
him but declined. •■■■9explained that work means give…
giuffre-maxwell
gov.uscourts.nysd.447706.1067.0
10 pg
…was “amenable to unsealing portions of
documents mentioning non-parties rather than waiting to unseal the entirety of a given document
until all non-parties have provided input.” Intervenors ask that the Court follow the approach set
forth in Dkt…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.26
27 pg
…how
the question was within the Court’s Order, the question was withdrawn and a different question
was posed: “Mr. Boies: Let me approach it this way.” … Did Ms. Ward tell you that?” The
questioning about the Farmers continues…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
…with
During a sworn taped statement, stated she met
Jeffrey Epstein through Haley Robson. Robson would approach females
who wished to work for him. ••■■~ stated she was asked to.work for
him but declined. •■■■9explained that work means give…
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