giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…asserts, without factual or legal support, that her financial
information is being sought “for the purpose of harassment and intimidation.” Because Ms.
Ransome failed to address the relevance argument asserted by the Motion, this issue should be
deemed admitted. Compare…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.12
7 pg
…arbiter in
the room.
Thus, for efficiency purposes and to protect Ms. Maxwell from harassment and
oppression, we request that the Court appoint a Special Master to preside over Ms. Maxwell’s
third deposition and be given the following powers:
…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…protecting deponent from
annoyance, embarrassment and harassment by denying party’s attempt to obtain personnel
records relating to non-party).
Courts are more vigilant with these protections when the discovery is being sought from a
non-party. “[T]he fact…
giuffre-maxwell
gov.uscourts.nysd.447706.503.0
21 pg
…The Privilege therefore protects "the
independence of the press and the need to allow the press to
publish freely on topics of public interest without harassment
9
Case 1:15-cv-07433-RWS Document 503 Filed 11/21/16…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…of privacy. A non-party should not be subjected to undue
harassment serving no admissible purpose.
9
Case 1:15-cv-07433-LAP Document 1332-8 Filed 01/08/24 Page 11 of 27
Without waiving such objections, a…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.0
56 pg
…These arguments
were made, and documents filed, for purposes of distraction and harassment, and have nothing to
do with the issues presented by the motion. This is classic abuse of the courts records and files.
The Response and Exhibits were…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.9
15 pg
…asserts, without factual or legal support, that her financial
information is being sought “for the purpose of harassment and intimidation.” Because Ms.
Ransome failed to address the relevance argument asserted by the Motion, this issue should be
deemed admitted. Compare…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…own, your Honor, doesn't seem to require a
3 nonparty witness to go through those burdensome and harassment
4 lengths.
5 THE COURT: But those statements have nothing to do
6 with this case.
7 MR. POTTINGER: Well, not…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…380 F.3d 110 (2d Cir. 2004) (per curiam)
(witnesses and third parties "possess strong privacy interests,
because being identified as part of a law enforcement
investigation could subject them to 'embarrassme nts and
harassment'" ), "with the deviant and the…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…R.D. 391 (E.D.Cal.2009)
(evidence of employer's current financial worth was relevant to issue of punitive
damages, and thus was discoverable in Title VII action alleging sexual harassment and
retaliation, where complaint sought punitive damages, deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.29_1
16 pg
…Giuffre and her
attorneys, not to mention the purposes of harassment.
Pursuant to the Rules, if requested documents are not yielded in a “reasonable inquiry,” Ms.
Giuffre is not obligated to expend all of her time and resources on a…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…R.D. 391 (E.D.Cal.2009)
(evidence of employer's current financial worth was relevant to issue of punitive
damages, and thus was discoverable in Title VII action alleging sexual harassment and
retaliation, where complaint sought punitive damages, deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.4
40 pg
…such an interrogatory
is merely for the purpose of imposing a burden on Ms. Giuffre and her attorneys,
not to mention the purposes of harassment.
Pursuant to the Rules, if requested documents are not yielded in a “reasonable
inquiry,” Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…Request in
that it represents a complete invasion of privacy. A non-party should not be subjected to undue
harassment serving no admissible purpose.
9
Without waiving such objections, a copy of non-party Sarah Ransome’s current passport…
giuffre-maxwell
gov.uscourts.nysd.447706.1334.1
29 pg
…protecting deponent from
annoyance, embarrassment and harassment by denying party’s attempt to obtain personnel
records relating to non-party).
Courts are more vigilant with these protections when the discovery is being sought from a
non-party. “[T]he fact…
giuffre-maxwell
gov.uscourts.nysd.447706.23.0
32 pg
…knew the statements were false because Defendant engaged in and
facilitated the sexual abuse of this minor child, therefore, they were made for the inappropriate
purpose of “bullying,” “harassment,” and “intimidation.” See Front v. Khalil, 24 N.Y.3d 713…
giuffre-maxwell
gov.uscourts.nysd.447706.1167.0
31 pg
…These arguments
were made, and documents filed, for purposes of distraction and harassment, and have nothing to
do with the issues presented by the motion. This is classic abuse of the courts records and files.
The Response and Exhibits were…
giuffre-maxwell
1320-28
32 pg
…prostitute I have been the
target of outright lies, innuendo, slander, defamation and salacious gossip and
harassment; headlines made up of quotes I have never given, statements I have
never made, trips with people to places I have never been…
giuffre-maxwell
gov.uscourts.nysd.447706.773.4
5 pg
…now in
prison, enticed investors by falsely claiming that they could buy into lucrative pending settlements in whistleblower,
sexual harassment and other cases.
Edwards’ court papers say he knew nothing of Rothstein’s schemes, and federal authorities later determined
Edwards…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.8_3
9 pg
…a plaintiff’s sexual history. The court took
guidance from F.R.E. 412, and held that in an alleged sexual harassment case questions about a
plaintiff’s prior sexual history would not be allowed. See also, A.W. v…
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