giuffre-maxwell
gov.uscourts.nysd.447706.1155.0_2
13 pg
…merit. Disagreeing with opposing
counsel’s arguments is not a basis for withholding them from public view.
This Court has already ruled that the same countervailing interests Ms. Maxwell asserts in
her present Objections were conclusory and speculative. See App…
giuffre-maxwell
gov.uscourts.nysd.447706.223.7
3 pg
…that it seeks or purports to require
production or disclosure of privileged or other protected matter. Mr. Epstein hereby asserts all
privileges, including his Fifth Amendment privilege against self-incrimination, the attorney-client
Case 1:15-cv-07433-RWS…
giuffre-maxwell
gov.uscourts.nysd.447706.956.0
3 pg
…into a non-prosecution agreement
with federal authorities.
In a 2014 court filing that has since been struck by the court and withdrawn by counsel,
Ms. Roberts, who asserts that she was a victim of Epstein, alleged, among other things…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.3
10 pg
…this case is the most expeditious manner in which to pursue their rights. Because
the background regarding their abuse is relevant to the Court’s assessment of whether to allow
them to join, their circumstances are recounted here briefly.
fashion…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…with
an additional two-week period granted to respond to Plaintiff’s First Request for Production of
Documents.6 The discovery was thus never stayed.
Plaintiff erroneously asserts that that discovery “did not commence in this matter until”
February 8…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…much
less discuss, Florida law, she has not carried that burden.)
Defendant asserts that she can force disclosure of the privileged communications between
Ms. Giuffre and her counsel under the “at issue” doctrine. To establish this alleged waiver,
Defendant’s…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…24(b), courts in this Circuit consider the following factors in assessing
whether to grant permissive intervention:
(i) whether permitting the intervention would unduly delay or prejudice the
adjudication of the dispute among the original parties to the litigation; (ii…
giuffre-maxwell
gov.uscourts.nysd.447706.1302.0
3 pg
…Catherine O’Hagan Wolfe, Clerk of Court
2
We rely on the same circumstances to assess both the timeliness of Rule 24(a) motions for
intervention as of right and Rule 24(b) motions for permissive interventions. See Floyd v…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…the Federal Rules of Civil Procedure provides
that the court may impose a range of sanctions, including dismissal or judgment by default,
preclusion of evidence, imposition of an adverse inference, or assessment of attorneys' fees and
costs. Fed. R. Civ…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.18
11 pg
…or
the importance of the discovery in resolving those issues. She simply fails to provide any
information by which the Court can assess these factors, and thus should not be permitted to
exceed the deposition limit based on her proffer…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
… Mr. Cassell asserts that the Palm Beach Police Report “showed the sexual
abuse was occurring on a daily basis” at the Epstein mansion, and thus “that [it] would have
made it obvious to a visiting guest that young girls were…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…Request 23: “All manuscripts and/or other writings whether published or unpublished, created in whole or in part by
Jane Doe #3 concerning Epstein and any of his agents or associates.”
20
Dershowitz asserts that before this May 11, 2011…
giuffre-maxwell
gov.uscourts.nysd.447706.1196.0
32 pg
…17 Ms. Giuffre, likewise, asserts certain privacy
18 interests that she argues outweigh the presumption of public
19 access in certain documents. The Court finds, as it did for
20 the last round of motions it considered for unsealing, that…
giuffre-maxwell
gov.uscourts.nysd.447706.1069.0
25 pg
…21 procedural history, but when the Second Circuit spoke with
22 regard to this issue, it was very clear that there had been no
23 effective individualized or particularized assessment of any
24 particular discovery item, deposition testimony, and the…
giuffre-maxwell
gov.uscourts.nysd.447706.1305.0
4 pg
…to the public’s
interest in monitoring federal courts’ exercise of their Article III powers.” App’x at 214. In
assessing each document, the District Court kept this “presumption of public access in mind” and
weighed it against “countervailing interests”…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.33
12 pg
…the Federal Rules of Civil Procedure provides
that the court may impose a range of sanctions, including dismissal or judgment by default,
preclusion of evidence, imposition of an adverse inference, or assessment of attorneys' fees and
costs. Fed. R. Civ…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.27
11 pg
…earlier email from Ms. Maxwell,
Mr. Gow knew what to do, which itself suggests prior direction from someone.
2
Plaintiff asserts that Mr. Barden is “nowhere to be found on any of these communications” between
Ms. Maxwell and Mr. Gow…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.1
8 pg
…that the court may impose a range of sanctions,
including dismissal or judgment by default, preclusion of evidence, imposition of an adverse
inference, or assessment of attorneys' fees and costs. Fed.R.Civ.P. 37(b); see Residential
Funding Corp…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…§ 985.054 make juvenile law enforcement
records confidential from members of the public, and states that information obtained by a law
enforcement agent participating in the assessment of a juvenile is confidential. Finally, certain of
the police reports implicate Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.1_1
13 pg
…054 make juvenile law enforcement
records confidential from members of the public, and state that information obtained by a law
enforcement agent participating in the assessment of a juvenile is confidential. These statutes apply
to the police reports involving Ms…