giuffre-maxwell
gov.uscourts.nysd.447706.1327.26
27 pg
… see also Kilkenny v. Greenberg Traurig, LLP, No. 05 CIV.
6578NRB, 2008 WL 371808, at *1 (S.D.N.Y. Feb. 7, 2008) (denying motion to compel where
specific questions and objection were not provided, noting rule 37.1 is…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.13_5
465 pg
…1 G Maxwell - Confidential
2 helping him in a very nominal way, maybe an
3 hour or two a year at sometime 2008 and 2009.
4 MR. PAGLIUCA: So if you are going
5 to be talking about general background…
giuffre-maxwell
gov.uscourts.nysd.447706.46.0
22 pg
…421 (S.D.N.Y. 2013) .............................................. 9
Gucci Am., Inc. v. Gucci, No. 07–CV–6820 (RMB)(JCF), 2008 WL 5251989, at *1
(S.D.N.Y. Dec. 15, 2008) .................................................................................. 12, 14, 15
GUS Consulting GMBH v. Chadbourne & Parke LLP…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…The origins of this case lie in a decade‐old criminal proceeding
against financier Jeffrey Epstein (“Epstein”). On June 30, 2008, Epstein
pleaded guilty to Florida state charges of soliciting, and procuring a
person under the age of eighteen for…
giuffre-maxwell
gov.uscourts.nysd.447706.995.0
11 pg
…and therefore cannot be set aside lightly.” Sealed Plaintiff v.
Sealed Defendant, 537 F.3d 185, 188-89 (2d Cir. 2008). For this reason, courts permit parties to
proceed anonymously only “in a limited number of exceptions.” Mottola v. Denegre…
giuffre-maxwell
gov.uscourts.nysd.447706.343.0
8 pg
…C.f. U.S. S.E.C.
v. Shehyn, 2008 WL 6150322, at *4 (S.D.N.Y. 2008) (“Whatever delay there may have been in
applying to the Spanish Central Authority was caused, in large part, by defendant Donald…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.39
36 pg
…8 circumstance in Palm Beach. Then we have the arrest that
9 happens of Jeffrey Epstein in 2006.
10 Thereafter, my client in 2008 is -- I'm sorry, she
11 receives from the U.S. government a victim notification letter…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.40
19 pg
…08-cv-80736-KAM pleadings to include:
a. Motion for Limited Appearance, Consent to Designation and Request
to Electronically Receive Notices of Electronic Filing (July 28, 2008)
(Doc. # 16)
b. Notice of Change of Address and Firm Affiliation (Apr. 9…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.33
24 pg
…the case at hand and on other litigation, provided that the party against whom
they are imposed was in some sense at fault.’” Szafrankowska v. AHRC Home Care Servs., Inc.,
2008 WL 186206, *1 (S.D.N.Y. Jan. 22…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.31
10 pg
…victims accusing the
federal government of violating the Crime Victims' Rights Act (CVRA) when it
made a secret 2008 plea deal with Epstein without informing them.
Dershowitz played a key role in negotiating a secret provision in Epstein's plea…
giuffre-maxwell
gov.uscourts.nysd.447706.364.0
32 pg
…against accusations that he had solicited sex workers and had
inappropriate sexual encounters with underage girls.1 Declaration of Alan M. Dershowitz
(“Dershowitz Decl.”) ¶¶ 6-7. In 2008, Epstein pleaded guilty to certain offenses involving sex
with minors. Id. ¶ 7…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…conducted by New York City Transit Authority); United States v.
Aref, 533 F.3d 72 (2d Cir. 2008) (finding that where classified
information presented at trial, if disclosed, would jeopardize
national security weighed against public access); Lugosch v.
Pyramid Co…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.19
106 pg
…G Maxwell - Confidential
2 helping him in a very nominal way, maybe an 2 Q. You can answer.
3 hour or two a year at sometime 2008 and 2009. 3 A. I have not any idea exactly of the
4 …
giuffre-maxwell
gov.uscourts.nysd.447706.55.21
69 pg
…versus Jeffrey 21 employed?
22 Epstein, defendant. Jane Doe, plaintiff, 22 A. December of 2008.
23 versus Jeffrey Epstein, et al, defendant. 23 Q. Was there a time you were employed in
24 Jane Doe 3, plaintiff, versus Jeffrey 24…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.3
26 pg
…10, 2011 Statement on behalf of Ghislaine Maxwell by Media agent Ross
Gow, attached hereto as Exhibit 2.
3. September 3, 2008 Victim Notification Letter, attached hereto as Exhibit 3.
4. May 1, 2009 Complaint in Jane Doe No. 102…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…their locations are, just in case
anything happens to me before the footage is released.
When my friend eventually had the courage to speak out and went to the police in 2008 to report
what had happened, nothing was done…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.16
10 pg
…625, 636 (D. Hawaii 2008) (holding that individuals designated only as
rebuttal experts could present limited testimony, could not testify as part of a party's case-in-
chief, and would not be allowed to testify “unless and until” the…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…162 (M.D. Pa. 2008) (there was no good
cause to issue protective order preventing discovery of defendants’ financial condition
until determination was made that punitive damages were warranted; plaintiffs stated
claim for punitive damages, and delaying discovery until after…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.18
50 pg
…W.D.Mo.1973) .................................................................................................. 30
Jane Doe 1 v. United States,
No. 9:08-cv-80736 (S.D. Fla. July 7, 2008).............................................................................. 38
Jane Does 1 and 2 v. United States,
950 F. Supp. 2d 1262 (S.D…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.9
21 pg
…the additional depositions would be unreasonably cumulative or
duplicative, the requesting party had a prior opportunity in
discovery to obtain the information sought, or the burden or
8360(NRB), 2008 WL 2073934 , at *5 (S. D.N.Y. May 8…
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