giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…is alleged by Ms. Roberts that Alan
Dershowitz is involved in having sexual relations with her, which he denies.
Ms. Roberts claims are obvious lies and should be treated as such and not publicized as
news, as they are defamatory…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.33
12 pg
…Giuffre was with Defendant and Epstein, namely, from 2000 - 2002.
Defendant has denied that she used those accounts to communicate, but she has not disclosed the
account she did use to communicate during that time, nor produce documents from it…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.1
8 pg
…this Court on June 20, 2016, granted in
part and denied in part Plaintiff’s Motion. Specifically, this Court held:
Federal Rule of Civil Procedure 26(f)(3)(C) requires the parties to state their views and
proposals as to…
giuffre-maxwell
gov.uscourts.nysd.447706.1105.0
8 pg
…Mr. Dershowitz’s last application to receive materials
protected by the Protective Order or otherwise filed under seal in the instant matter. The Court
properly denied that application – which constituted Mr. Dershowitz’s third attempt to bypass the
Protective Order…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…excessive and redundant briefing on these issues, resulting in no additional
production. Plaintiff’s Motion must be denied because no “undisclosed” email account exists
and Ms. Maxwell has fully complied with this Court’s Orders.
ARGUMENT
I. PLAINTIFF HAS FAILED…
giuffre-maxwell
gov.uscourts.nysd.447706.1071.0
13 pg
…s request on the merits without
further briefing.
For the reasons that follow, Mr. Dershowitz’s request is
denied. In addition, the Court rules that certain discovery
materials from the Maxwell case are not properly in possession of
Plaintiff Virginia…
giuffre-maxwell
gov.uscourts.nysd.447706.1264.0
1 pg
…the parties, and non-parties have endeavored to
adhere.
Accordingly, TGP’s request to intervene and unseal should be denied.
Respectfully Submitted,
KRIEGER KIM & LEWIN LLP
By:…
giuffre-maxwell
gov.uscourts.nysd.447706.751.12
3 pg
…three years she worked for Epstein, she was 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…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…Ms. Giuffre
sought relief from the Court numerous times:
1
Plaintiff’s Response in Opposition to Defendant’s Motion to Stay Discovery (DE 20)
- Defendant’s Motion to Stay - Denied (DE 28).
Plaintiff’s February 26, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…to Ms. Giuffre’s
confidentiality designation is without merit, and it is for improper purposes. Therefore, it should
be denied.
Ms. Giuffre moved to maintain her confidentiality of highly sensitive documents. They
are police reports involving Ms. Giuffre, including two…
giuffre-maxwell
gov.uscourts.nysd.447706.1059.0
3 pg
…filed under seal Oct. 5,
2017). In a sealed opinion this Court denied the motion. It ruled that the Protective Order did
not extend beyond the completion of discovery or beyond the termination of the case, which
the Court determined…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…Giuffre was with Defendant and Epstein, namely, from 2000 - 2002.
Defendant has denied that she used those accounts to communicate, but she has not disclosed the
account she did use to communicate during that time, nor produce documents from it…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.43
4 pg
…with him three
times when she was 17 at Jeffrey Epstein's luxury Caribbean Island home and in New
York and London, all denied by Prince Andrew.
VICTORIA MURPHY, UK MIRROR ROYAL CORRESPONDENT: If this doesn't go away
quickly…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.20
21 pg
…As
set forth below, this motion is granted in part and denied
in part.
2 . Defendant Ghislaine Maxwell ("Maxwell " ) or ("Defendant " )
has moved to compel Plaintiff to disclose a ll eged on - go in g
criminal investigations by law enforcement…
giuffre-maxwell
gov.uscourts.nysd.447706.1294.0
11 pg
…their December 7 response letters to this
Court and their briefs in the Court of Appeals. (Dkt. no.
1292.) Ms. Giuffre submitted a letter response requesting that
Doe 171’s request be denied. (Dkt. no. 1293.)
1 On December 5…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…Ms. Giuffre
sought relief from the Court numerous times:
1
Plaintiff’s Response in Opposition to Defendant’s Motion to Stay Discovery (DE 20)
- Defendant’s Motion to Stay - Denied (DE 28).
Plaintiff’s February 26, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1062.0
7 pg
…marks Dershowitz’s second – or, by some measures, third – attempt to make an end-
run around this Court’s carefully constructed unsealing protocol. Just as the Court denied
Dershowitz’s prior attempts, it should deny this one. 1
A. This…
giuffre-maxwell
gov.uscourts.nysd.447706.363.14
2 pg
…18, 20 and 23.
The motion is denied as to the other requests, but a confidentiality order shall be entered.
Regarding the deposition: The depo shall be limited to 4 hours without prejudice to request additional time in
the future…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…to Ms. Giuffre’s
confidentiality designation is without merit, and it is for improper purposes. Therefore, it should
-
be denied.
Ms. Giuffre moved to maintain her confidentiality of highly sensitive documents. They
are police reports involving Ms. Giuffre, including two…
giuffre-maxwell
gov.uscourts.nysd.447706.1029.0
2 pg
…after considering the parties’ arguments, held: “The motion to compel
additional data is denied at this time.” Sealed November 10, 2016 Hearing Transcript at 40:7–8.
The fact that the motion was decided without prejudice has no bearing on…
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