giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…Defendant seeks a “copy of her
current driver’s license.” Non-party Ransome is already fearful for her life and has been
followed at least once since she disclosed the abuse she endured at the hands of Defendant and
Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.10
469 pg
…nature.
20 The witness has expressed to
21 me fears of harassment and the
22 belief that she's being followed,
23 and my understanding is that
24 there are other witnesses that
25 have had similar fears and
…
giuffre-maxwell
gov.uscourts.nysd.447706.1119.0_3
4 pg
…Martindell, 594 F.2d at 296, and the Second Circuit and district courts within
have uniformly followed Martindell and its progeny to deny government requests to modify
protective orders in private litigation to obtain material for their own investigations. See…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.7
469 pg
…that nature.
20 The witness has expressed to
21 me fears of harassment and the
22 belief that she's being followed,
23 and my understanding is that
24 there are other witnesses that
25 have had similar fears and
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.36
10 pg
…then the use of Mr. Epstein’s video deposition
testimony is the procedure which should be followed in this case.
While requiring Mr. Epstein to invoke his Fifth Amendment privilege in front of the jury will
yield not even a…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…after he
started the investigation into the crimes that took place at the Palm Beach mansion, he was
followed by strange men and “investigated”. He also has made public statements that he sent to
victims regarding the failure of the…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.9
29 pg
…Defendant seeks a “copy of her
current driver’s license.” Non-party Ransome is already fearful for her life and has been
followed at least once since she disclosed the abuse she endured at the hands of Defendant and
Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1192.0_3
3 pg
…Protocol, whether the
Sealed Materials should be unsealed. The Dershowitz parties do not need a list of Does or
further clarification to ensure that this Court Order is followed. Pending this Court’s ruling on
the unsealing of specific documents…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.7
18 pg
… Sure. And when you got the case six
22 months later, if there hadn't been follow-up, you
23 would have followed up on it, right?
24 MS. SCHULTZ: Object to form.
25 THE WITNESS: Correct.
MAGNA9 LEGAL SERVICES…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.4_1
29 pg
…In her sworn declaration, she
discussed the following attorney communications:
Her conversation with Brad Edwards in 2011 when she first told him her story. This was
followed by a telephone conversation with Edwards and his attorney, Scarola, which was
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.40
3 pg
…bringing out thi s story as long as everything that is printed is I 00%
factual and prove worthy.
bu
There is also another major paper that has followed the story for a while and …
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…2
Ms. Ransome testified that she was “followed at least once,” but that was after she contacted the New
York Post reporter and blames that reporter for sharing her secret. The supposed “following” occurred prior to Ms.
Ransome’s name…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…Defendant seeks a “copy of her
current driver’s license.” Non-party Ransome is already fearful for her life and has been
followed at least once since she disclosed the abuse she endured at the hands of Defendant and
Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…defend himself against charges of gross
wrongdoing, Dershowitz followed his own prescription and took his defense to the court of
public opinion where he had an audience willing to ignore both law and facts. The lawyer
victims of Dershowitz's…
giuffre-maxwell
gov.uscourts.nysd.447706.164.0
29 pg
…In her sworn declaration, she
discussed the following attorney communications:
Her conversation with Brad Edwards in 2011 when she first told him her story. This was
followed by a telephone conversation with Edwards and his attorney, Scarola, which was
…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
…thought she appeared to “about 25” years old. It turned
out that my estimate was correct. This exchange followed:
[DERSHOWITZ]: … I must say that during the recess, my wife
Googled Tatiana and found out that she was, in fact…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.9
15 pg
…2
Ms. Ransome testified that she was “followed at least once,” but that was after she contacted the New
York Post reporter and blames that reporter for sharing her secret. The supposed “following” occurred prior to Ms.
Ransome’s name…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…Maxwell in the Southern District of New York. Giuffre alleged
that Maxwell had defamed her through this and other public
statements. Extensive and hard‐fought discovery followed. Due to the
volume of sealing requests filed during discovery, on August 9…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…after he
started the investigation into the crimes that took place at the Palm Beach mansion, he was
followed by strange men and “investigated”. He also has made public statements that he sent to
victims regarding the failure of the…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…had originally contacted this
16 reporter using her own cell phone, and she claims that after
17 she contacted the reporter in October using her cell phone,
18 that she got followed around Spain by some unknown people. She
19…
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