giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…Clinton were included in her initial Rule 26 disclosures served on November 11, 2015 and two of
the six were specifically mentioned in Plaintiff’s Complaint.
Finally, the fact that witness Rinaldo Rizzo had a deposition re-scheduled from April…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.32
4 pg
…the same freely and vo/untarif;· for the uses and purposes
therein mentioned.
[SEAL]
offtera/ seal the d.iy and year 1asl above written.
Hsiao-Chi…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…There are a few groups of people, his office in New
York and I guess --
***
Q. Okay. The other people mentioned as co-conspirators are Sarah Kellen, Adriana Ross, and
Nadia Marcinkova. So we'll get to them in a…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.9
10 pg
…money to bring her over;
14 however, they never called her to come.
15 Q. And then I believe you mentioned that one
16 of your physical fitness instructors, you brought a
17 physical fitness instructor; was that correct?
18 …
giuffre-maxwell
gov.uscourts.nysd.447706.1328.30
40 pg
…LAP Document 1328-30 Filed 01/05/24 Page 5 of 40
103
1 A I did not.
2 Q When the FBI interviewed you, did you
3 mention this to them?
4 A I mentioned -- anything they asked me…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…or even the knowledge of Alan
Dershowitz’ name – is even more apparent. Prior to the December 2014 joinder Motion, there is
not a single mention of Mr. Dershowitz in any pleading related to Plaintiff. In Churcher’s March
2011 publications…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.14
9 pg
…That is prejudicial. It is Defendant who has behaved
improperly in repeated depositions, and Plaintiff should not be required to pay for a special
master.
A final point needs to be mentioned. As recounted in the background section above, the
…
giuffre-maxwell
gov.uscourts.nysd.447706.1069.0
25 pg
…heard on reliance?
4 All right. The next question I have is: How are we
5 to protect the interests of the nonparties or third parties who
6 either produced materials or were mentioned in the materials?
7 MR. COOPER:…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.11
8 pg
…a couple of 7 Q. Mr. Rodriguez, you mentioned the last
8 questions. 8 time about a lady who was an obvious professional
9 EXAMINATION …
giuffre-maxwell
gov.uscourts.nysd.447706.1050.0
12 pg
…and our proposal is that we begin with Doe I
11 and II together because they are mentioned in the same item.
12 My proposal would be for the Original parties to confer and to
13 propose five motions or…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.44
14 pg
…Do you agree that these corporations that
5 A. Not that I recall. 5 I just mentioned were utilized by Jeffrey Epstein in
,.
'O Q. Do you ever recall being in Ohio? 6 an attempt to have sexual relationships with…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…Giuffre is copied on the message. Ms. Churcher mentions
Professor Dershowitz as one of Epstein’s lawyers, together with Kenneth Starr, but not as an
abuser:
Hi Jarred
Hopefully you have Virginia' s book pitch by now.
She has some…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…re referring to.
3 "Q. So was there -- during your time, was there no other --
4 you mentioned information on a computer. Was there any
5 hard-copy document you would refer to to find someone's number?
6 "A…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.22
40 pg
…LAP Document 1257-22 Filed 05/03/22 Page 5 of 40
103
1 A I did not.
2 Q When the FBI interviewed you, did you
3 mention this to them?
4 A I mentioned -- anything they asked me…
giuffre-maxwell
gov.uscourts.nysd.447706.1071.0
13 pg
…21:2-7.)
6
Case 1:15-cv-07433-LAP Document 1071 Filed 07/01/20 Page 7 of 13
3. Mr. Dershowitz’s Request to Modify the Maxwell Protective
Order
As mentioned above, see supra at 1, Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.1154.0_5
3 pg
…trauma and did not want to be involved in the proceedings at all. Doe
#84’s name was mentioned in some of the sealed summary judgment pleadings, and the
Second Circuit sua sponte redacted the name and the deposition testimony…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…50).
A. Non-Response from Does 1 and 2 Not Dispositive of Countervailing Interests
Plaintiff argues that all documents mentioning Does 1 and 2 should be released because
neither requested excerpts nor interposed any objection. She also claims that some…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.29
5 pg
…saw except the two girls
24 MR. CRITTON: Let me just note my objection, 24 that I mentioned that I think it was underage was
25 as T did in A. Rod's deposition or Mr. Rodriguez's 25 N…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.22
22 pg
…WITH A DIRTY BLONDE GOATEE AND DIRTY BLONDE
SAID THAT THE SUSPECT NEVER MENTIONED A PLACE OF
E DURING THEIR CONVERSATION.
AT THIS TIME SAID SHE DID NOT FEEL COMFORTABLE
…
giuffre-maxwell
gov.uscourts.nysd.447706.1034.0
16 pg
…2019).
4. Notice of Appellate Rights: The Protocol will include the
provision notifying non-parties of their appellate rights
with respect to any decision to unseal a document mentioning
their name. That provision will provide that “[a]n order
from…