…are authorized to accept service of a subpoena for Jeffrey Epstein's testimony in the Maxwell action. You explained that it would be Epstein's position that he would be invoking his Fifth Amendment privilege as to all questions relating…
…You can answer. 5 of this lawsuit is, which would be, as 6 A. I just explained. 6 you've termed it, sexual trafficking of 7 A. I spent the entire time talking to 7 Ms. Roberts. 8 Virginia's…
…and Jane Doe #2 even though federal charges were never filed. DE 189. The Court explained that because the NPA barred prosecution of crimes committed against them by Epstein, they had “standing” to assert violations of the CVRA rights. Id…
…and because it is anticipated that confidential matters will be discussed. Ms. Giuffre requests expedited consideration of these materials. As the Court recalls, in her opposition to Bradley J. Edward’s pro hac vice motion, Defendant briefly mentioned that Edwards…
…172 199, and 230 (ECF No. 1068-1) later today. By order dated October 19, 2020, after expedited briefing and a hearing held on October 13, 2020, the Second Circuit affirmed this Court’s order (ECF No. 1126), rejecting Maxwell…
…decisions in Twombly and Iqbal, the United States Court of Appeals for the Third Circuit explained that a District Court must undertake the following three steps to determine the sufficiency of a Complaint: First, the court must take note of…
… 2. As Plaintiff explained in making this suggested edit to the Protocol, providing notice to all remaining Non-Parties speeds up the unsealing process by minimizing the number of Non-Party names that need to be redacted from future materials…
…19/20 Page 3 of 13 criminal matter, this Court held, “[a]gain, Ms. Maxwell has relied on [ipse] dixits and has not explained how the sealed material, if released, could, as she posits, ‘inappropriately influence potential witnesses or victims.’”…
…continues to grow without limitation: more and more famous people, more lurid accounts of tawdry sexual encounters, and more exploitive circumstances. Giuffre’s stories have proven wildly contradictory and, even by her own words, have been definitively proven untrue. 4…
…1999. .................................... 56 2. The January 2015 statement accurately denied that Ms. Maxwell “regularly participate[d] in Epstein’s sexual exploitation of minors” and that “the Government knows” such fact. ..................…
…2016. Plaintiff’s counsel still has not explained why they waited more than two months to disclose the witness, nor why they represented to the Court that she was a “recent” discovery. 1 Case 1:15-cv-07433-LAP…
… She explained that she lived in Palm Beach 25 and didn't want butlers because they're too stuffy. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-25 Filed 01/05/24 Page 4 of 10 Page…
…and Jane Doe #2 even though federal charges were never filed. DE 189. The Court explained that because the NPA barred prosecution of crimes committed against them by Epstein, they had “standing” to assert violations of the CVRA rights. Id…
…provide a vehicle for this Court to protect a non-party from a harassing, burdensome and unnecessary subpoena. As explained below, non-party Jane Doe No. 3 should be protected from having to be deposed in this matter or produce…
…the Court could take expedited briefing on DE 143 and its related pleadings and rule on any Non- Party objections that were interposed to unsealing their names in that set of documents. This would require amending the Order and Protocol…
…claim the content of select excerpts are incorrect. Id. at 3. As was explained in Plaintiff’s previous submission filed on January 12, 2022, opposing the first tranche of non-party objections, the Court is not charged with making a…
…to be considered under the Order and Protocol for Unsealing Decided Motions are discovery motions that were resolved by Judge Sweet. ECF No. 1044 at 1. Therefore, as the Second Circuit explained, “[t]he remaining sealed materials at issue here . . …
…would either enable or require her to do so.” Id. Plaintiff never responded. She also has not explained when or how Ms. Maxwell “acknowledged” her “plans to call Mr. Gow for testimony at trial,” nor why that is relevant to…
…of modification. As the court in EDPM explained: An examination of Second Circuit case law reveals the following factors are relevant when determining whether a party has reasonably relied on the protective order: (1) the scope of the protective order;…
…response to Dershowitz’s intervention motion. McCawley Decl., Exhibit 3, Response to Motion to Intervene.3 The response explained that the allegations against Dershowitz were relevant to at least eight separate issues in the CVRA case. Id. at 18-26…
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