giuffre-maxwell
gov.uscourts.nysd.447706.1256.16
30 pg
…Defendant’s involvement in
the sexual abuse of young girls, Defendant’s discovery arguments have become more removed
from the merits of this case and increasingly strident in their tone. The latest example of this
genre is the instant motion…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.7
30 pg
…Defendant’s involvement in
the sexual abuse of young girls, Defendant’s discovery arguments have become more removed
from the merits of this case and increasingly strident in their tone. The latest example of this
genre is the instant motion…
giuffre-maxwell
gov.uscourts.nysd.447706.135.0
37 pg
…in Resp . to Pl.'s Mot. to Compel the Productio n of
Documents S ub ject to Improper Claim of Priv. at 4-6 (emphas i s
removed ) ("Pl.' s Reply ") .
9
176 t'lisc. 2_d ~05, 609, …
giuffre-maxwell
gov.uscourts.nysd.447706.1167.0
31 pg
…the
names of Non-Parties whose time
to object has expired should be
removed.
1…
giuffre-maxwell
1320-28
32 pg
…knowledge from 94 to 69, inexplicably removing 34 names, but adding 12 more. She removed,
18
Case 1:15-cv-07433-LAP Document 1320-28 Filed 01/03/24 Page 22 of 32
for example, witnesses Andrea Mitrovich and…
giuffre-maxwell
1320-13
45 pg
… . : 1-05- 000368 (Continued)
introduced himself as Jeff. l■■•advised she recalled she and
removed their clothing down to their panties, Epstein lay on his
stomach area and they provided a massage on his legs and feet area. I
asked…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.19
30 pg
…Defendant’s involvement in
the sexual abuse of young girls, Defendant’s discovery arguments have become more removed
from the merits of this case and increasingly strident in their tone. The latest example of this
genre is the instant motion…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.19_2
32 pg
…knowledge from 94 to 69, inexplicably removing 34 names, but adding 12 more. She removed,
18
Case 1:15-cv-07433-LAP Document 1137-19 Filed 10/22/20 Page 22 of 32
for example, witnesses Andrea Mitrovich an…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.14
30 pg
…Defendant’s involvement in
the sexual abuse of young girls, Defendant’s discovery arguments have become more removed
from the merits of this case and increasingly strident in their tone. The latest example of this
genre is the instant motion…
giuffre-maxwell
gov.uscourts.nysd.447706.57.2
30 pg
…It was
copied for a Mr Mian, a sales director of LGH, with names blanked out. In due course it
was sent to Powerhouse's lawyers, on 7th March (which was the infringement relied on
and established at the trial…
giuffre-maxwell
gov.uscourts.nysd.447706.751.12
3 pg
…made to entertain his friends and named Prince
Andrew and Dershowitz as two men she had sex with.
Both men have denied having sex with Roberts, and Dershowitz is trying to get his name removed from the suit,
claiming Roberts…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.42
9 pg
…who says that the lawyer
sexually abused her when she was a teenager. Dershowitz is demanding his name be
removed from her lawsuit and is asking for damages. Roberts says that a wealthy
investor forced her into sex slavery when…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.16
22 pg
…1331.
2. Plaintiff files this Complaint under a pseudonym in order to protect
her identity because this Complaint makes allegations of a sensitive sexual nature
and disclosure of Plaintiffs name publicly will cause firther harm to her.
3. At all…
giuffre-maxwell
gov.uscourts.nysd.447706.1187.0
3 pg
…Even where Ms.
Giuffre agrees to remove the confidentiality
designations for such materials produced in
Maxwell, the parties shall not publicly disclose or
file on the public docket the names or identifying
information of non-party Does (except for Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.2.0
2 pg
…of the United States in September 1974, 1s required for use of the Clerk of Court for the purpose of
initiating the civil docket sheet.
PLAINTIFFS DEFENDANTS
Virginia L. Giuffre …
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…when the patient stated that she had to urinate. [REDACTED] was
assisting [REDACTED] remove her panties when she noticed grass and twig particles in
the crotch area of [REDACTED] panties as well as a small amount of blood, an unknown
…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…Now, after having created a last-
minute scramble to conduct discovery on facts far removed in time and circumstance from
Plaintiff’s defamation claim, Plaintiff now complains that too much is being asked of her
“witness.” Plaintiff protests that the…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…if the Court allows Plaintiff Virginia
Giuffre to remove the confidentiality designation concerning the Ransome deposition—an action
that would require modification of the Protective Order in this case —it also simultaneously
remove the confidentiality designation from several related emails…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…as to all other judicial records, the Court should
balance the competing interests of public access and non-party privacy and reputational interests
by redacting the names and other identifying information of the non-parties. We further propose
for the…
giuffre-maxwell
gov.uscourts.nysd.447706.29.1
18 pg
…a Complaint must be dismissed for “failure to state a claim upon
which relief can be granted.” Detailed factual pleading is not required – Rule 8(a)(2) calls for a
1
This case was removed to this Court by Defendant…
Comments