…The EarthLink account The second account, is, as Ms. Maxwell has repeatedly explained to Plaintiff’s counsel, an account that she does not recognize, that she does not recall having ever logged onto, and for which she has no password…
…not the case. Guests having massages did not have massages in Mr. Epstein’s private bedroom suite. This area was private and off- limits to guests, which I explained to the lawyers during my deposition. Id. at ¶¶ 9-10. 40…
… 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 1328-30 Filed 01/05/24 Page 9 of 40 Page…
…The government has not provided Maxwell with a copy of the subpoena, but the record shows that the subpoena was incredibly broad and, as explained below, ultimately unlawful. The subpoena violated the Fourth Amendment because it was overbroad and because…
…claim that a communication between Ms. Maxwell and Mr. Epstein related to a possible response to Plaintiff’s published false claims concerning Ms. - Maxwell is somehow “new,” not previously explored, or relevant is provably inaccurate. The entirety of Plaintiff’s…
…frequently was the case, numerous interests could be identified sufficient to rebut the presumption of access. The three counsel of record completed this project within the time constraints imposed by the Court in this expedited proceeding. That is not a…
…discovery is a valuable right and should not be unnecessarily restricted, the ‘necessary’ restriction may be broader when a non-party is the target of discovery.”). As explained above, this non-party was asked a host of questions that ran…
…DE 466. As explained in length in the motion, these two documents involved central issues in the case, 2 Case 1:15-cv-07433-LAP Document 1332-14 Filed 01/08/24 Page 4 of 9 including Defendant’s…
…01/05/24 Page 13 of 31 innocence. But this inference is inconsistent with Ms. Giuffre’s description of the manuscript, in which she explained “[n]ot everything in it is – not everything is in there . . ..” McCawley Dec. at 13…
…See Confidential App’x at 167–74. 2 The District Court explained that the relevant materials were “largely discovery motions and related papers [for] which [the] presumption of public access is somewhat less weighty than for a dispositive motion,” but…
…07433-LAP Document 1206-2 Filed 02/04/21 Page 18 of 23 had in the Chemical Bank case. In no uncertain terms, explained why she had haled the prosecutor back into court: Ex. E, p 2. In Chemical Bank…
…Evid. 412 is applicable to discovery “have found that Rule 412 has significance in the resolution of a discovery dispute”). “As explained in the Advisory Committee Notes regarding the 1994 amendments to Rule 412, ‘[t]he rule aims to safeguard…
…law). The Second Circuit has explained that “the item filed must be relevant to the performance of the judicial function and useful in the judicial process in order for it to be designated a judicial document.” Amodeo I, 44 F…
…s Special Agent Pryor, at the end of paragraph 6 7 says that the CW, who I believe is Mr. Edwards, explained this 8 conversation with Rodriguez. And according to CW, Rodriguez 9 explained that he, Rodriguez, not anyone else…
…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 decision on the credibility of deponents or of…
…emphasis added). And the Court has explained in no uncertain terms that parties were justified in their expectation that the Protective Order would not be modified “for purposes external to the lawsuit in which it was entered.” Id. at 12…
…The second account, , is, as Ms. Maxwell has repeatedly explained to Plaintiff’s counsel, an account that she does not recognize, that she does not recall having ever logged onto, and for which she has no password. See DE 320…
… She explained that she lived in Palm Beach 25 and didn't want butlers because they're too stuffy. Case 1:15-cv-07433-LAP Document 1257-22 Filed 05/03/22 Page 9 of 40 Page 9 1 And…
…their entirety. Asked to explain how those materials came into the firm’s possession, attorneys from Cooper & Kirk explained that they had obtained access to the materials because Ms. Giuffre retained them “both to represent her in [Giuffre v. Dershowitz…
…13 at 1–2. Nor did Judge McMahon need to impose obligations on the Government; as she explained: “the fact that the request comes from a grand jury, whose proceedings are by law conducted in secret, … gives Maxwell[3…
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