giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…and reputation that may
accompany public disclosure of hard‐fought, sensitive litigation. We
therefore clarify the legal tools that district courts should use in
safeguarding the integrity of their dockets. Accordingly, we VACATE
the District Court’s orders entered on…
giuffre-maxwell
gov.uscourts.nysd.447706.978.0
27 pg
…and reputation that may
accompany public disclosure of hard‐fought, sensitive litigation. We
therefore clarify the legal tools that district courts should use in
safeguarding the integrity of their dockets. Accordingly, we VACATE
the District Court’s orders entered on…
giuffre-maxwell
gov.uscourts.nysd.447706.977.0
27 pg
…and reputation that may
accompany public disclosure of hard‐fought, sensitive litigation. We
therefore clarify the legal tools that district courts should use in
safeguarding the integrity of their dockets. Accordingly, we VACATE
the District Court’s orders entered on…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…in its in camera
review before ordering Defendant to produce them. Yet Dershowitz waited until after discovery closed and until
after he was safe from receiving a notice of deposition in this matter, before he filed his intervention motion.
Unsurprisingly…
giuffre-maxwell
gov.uscourts.nysd.447706.1100.1
13 pg
…and not for any civil proceeding or any purpose
other than the defense of this action;
b) Shall be maintained in a safe and secure
manner;
c) Shall be reviewed and possessed by the
Defendant in hard copy solely in…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…university, which she desperately wanted - and
would win. The girls’ mother told me by phone that she had thought her daughters would
6
be safe under Epstein’s roof, not least because he phoned her to reassure her, and…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…
Has not had a haircut in a year and is being moved ‘from cell-to-cell’ for her own
safety.
2/13
Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 45 of 161…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…university, which she desperately wanted - and
would win. The girls’ mother told me by phone that she had thought her daughters would
6
be safe under Epstein’s roof, not least because he phoned her to reassure her, and…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…win. The girls’ mother told me by phone that she had thought her daughters would
6
Case 1:15-cv-07433-LAP Document 1327-5 Filed 01/05/24 Page 7 of 17
be safe under Epstein’s roof…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.16
10 pg
…Okay. After speaking to the police or while speaking to the police, do you remember
telling them that you're not safe because you're talking about this?
MR. PAGLIUCA: Object to form and foundation.
THE WITNESS: Yes.
BY MR…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.1
17 pg
…win. The girls’ mother told me by phone that she had thought her daughters would
6
Case 1:15-cv-07433-LAP Document 1218-1 Filed 07/15/21 Page 7 of 17
be safe under Epstein’s roof…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.14
6 pg
…s gonna get me. You guys realize that, right? ... I'm not safe now. I'm
not safe.
Recarey: Why do you say you're not safe? Has he said he's hurt people before?
Alison: Well, I've heard…
giuffre-maxwell
gov.uscourts.nysd.447706.1100.0
16 pg
…and not for any civil proceeding or any purpose
other than the defense of this action;
b) Shall be maintained in a safe and secure
manner;
c) Shall be reviewed and possessed by the
Defendant in hard copy solely in…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.22
31 pg
…in its in camera
review before ordering Defendant to produce them. Yet Dershowitz waited until after discovery closed and until
after he was safe from receiving a notice of deposition in this matter, before he filed his intervention motion.
Unsurprisingly…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.18
8 pg
… Okay. After speaking to the police or
16 while speaking to the police, do you remember
17 telling them that you're not safe because you're
18 talking about this?
19 MR. PAGLIUCA: Object to form and
20 foundation…
giuffre-maxwell
gov.uscourts.nysd.447706.370.0
17 pg
…value of home; filing of
tax returns, savings, checking, or other bank deposits, investment deposits, ownership of a safe
deposit box, cash on hand and pending legal actions for money. Evans v. Celise, No. 92-civ-
8430 (PKL), 1994 WL…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.19
17 pg
…value of home; filing of
tax returns, savings, checking, or other bank deposits, investment deposits, ownership of a safe
deposit box, cash on hand and pending legal actions for money. Evans v. Celise, No. 92-civ-
8430 (PKL), 1994 WL…
giuffre-maxwell
gov.uscourts.nysd.447706.15.0
29 pg
…the 10th Circuit has deemed it a “safe presumption” that Colorado Supreme Court would adopt the various
provisions of the Restatement (Second) of Torts (1977) as part of “its common law of defamation” based on its
decisions and Uniform Jury…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…harass and intimidate Ms. Giuffre who was a victim of sexual trafficking.
a. Due to safety concerns with respect to Ms. Giuffre and her minor children,
she is not at liberty to reveal her present residential location. To ensure that…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…and advocate
for the public interest, safety, healthand well-being of persons in the Virgin Islands.
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 3 of 55
Case 1:15-cv-07433-LAP Document…
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