giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…to
learn that this clash of the legal titans has been averted, preventing the allegations on all sides
from being explored in greater depth in open court.
UPDATE (4/9/2016, 10:55 a.m.): Here is the statement of…
giuffre-maxwell
gov.uscourts.nysd.447706.1008.0
5 pg
…1995). As the Second Circuit explained on appeal in this matter, a document is relevant
to the performance of the judicial function “if it would reasonably have the tendency to influence
Case 1:15-cv-07433-LAP Document 1008…
giuffre-maxwell
gov.uscourts.nysd.447706.1329.0
3 pg
…the alphabetical order of
1 With respect to the remaining Does, the Court has explained its
reasons for declining to unseal their names, and any party
dissatisfied with those reasons can appeal to the Court of Appeals.
2
the list…
giuffre-maxwell
gov.uscourts.nysd.447706.1099.0
4 pg
…7 days, and that the Original Parties file letters with the Court 21 days thereafter advising
the Court of any further suggested changes to the Protocol based on how many Non-Parties request
excerpts.1
1
As explained below, Plaintiff…
giuffre-maxwell
gov.uscourts.nysd.447706.1128.0_4
1 pg
…172 199, and 230 (ECF No. 1068-1) later today.
By order dated October 19, 2020, after expedited briefing and a hearing held on October
13, 2020, the Second Circuit affirmed this Court’s order (ECF No. 1126), rejecting Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.37
11 pg
… She explained that she lived in Palm Beach
25 and didn't want butlers because they're too stuffy.
MAGNA& LEGAL SERVICES
Case 1:15-cv-07433-LAP Document 1328-37 Filed 01/05/24 Page 4 of 11
Page…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…and Jane Doe #2 even though federal
charges were never filed. DE 189. The Court explained that because the NPA barred
prosecution of crimes committed against them by Epstein, they had “standing” to assert
violations of the CVRA rights. Id…
giuffre-maxwell
gov.uscourts.nysd.447706.1227.0
2 pg
…Tr. of July 1, 2021 Ruling at 7:9–14. As the Court
explained during its most recent ruling, if there is identifying information about Doe himself that
he contends must be redacted, he may request that relief under seal…
giuffre-maxwell
gov.uscourts.nysd.447706.1095.0
2 pg
…file the exhibit under
seal is GRANTED pending review of the matter and without prejudice to reconsideration nostra
sponte. It is further ORDERED that the appeal is expedited. Appellant’s principal brief must be
filed on or before August 20…
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
…DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 31 Filed 01/28/16 Page 3 of 22 3
G1ETGIUA
1 statements that are referenced but never explained in
2 paragraphs 31 and 34?…
giuffre-maxwell
gov.uscourts.nysd.447706.1289.0
3 pg
…the scandalous
and intimate activities described in most or all of the Confidential Records.” Id. at 3. That is also
untrue. As the Court explained in its November 18, 2022, ruling, Doe 171 filed a federal lawsuit
against Julie Brown…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.12
35 pg
… She explained that she lived in Palm Beach
25 and didn't want butlers because they're too stuffy.
MAGNA9 LEGAL SERVICES
Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 4 of 35
Page…
giuffre-maxwell
gov.uscourts.nysd.447706.1135.0_6
1 pg
…regarding her proposed redactions during a
telephone conference at 1 p.m. today. While undersigned counsel explained the bases for her
disagreement and pointed out other areas that should be redacted, Ms. McCawley simply
stated that she disagreed without explanation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.599.0
12 pg
…Ms. Giuffre has correctly explained why Taylor should not be
allowed to opine on
The remaining opinions offered by Taylor would not be relevant or helpful to the jury,
which is why Taylor should be precluded from testifying at all…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.7
9 pg
…MENNINGER: Objection, hearsay.
12 BY MS . MCCAWLEY:
13 Q. You can answer.
14 A. He explained to me that, in his opinion,
15 he needed to have three orgasms a day. It was
16 biological, like eating.
17 Q. And…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.18
23 pg
…P . C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 1325-18 Filed 01/04/24 Page 4 of 23
3
GlETGIUA
1 statements that are referenced but never explained in
2 paragraphs 31 and 34? In…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…2016. Plaintiff’s counsel still has not explained why they waited more than two
months to disclose the witness, nor why they represented to the Court that she was a “recent” discovery.
1
BACKGROUND
Plaintiff first identified Sarah Ransome…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.43
12 pg
…or at a minimum, warrants
allowing an independent third party to conduct a forensic review of all of Defendant’s electronic data
as explained further herein.
I. DEFENDANT’S UNDISCLOSED ACCOUNT
1
Case 1:15-cv-07433-LAP Document…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…. “Q. Did Jeffrey
ever tell you why he received so many massages from so many different girls? A. He
explained to me that, in his opinion, he needed to have three orgasms a day. It was
biological, like eating.” Id…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…and Jane Doe #2 even though federal
charges were never filed. DE 189. The Court explained that because the NPA barred
prosecution of crimes committed against them by Epstein, they had “standing” to assert
violations of the CVRA rights. Id…
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