giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…of previous
public access to the documents; (3) the fact that someone has objected to
disclosure, and the identity of that person; (4) the strength of any property and
privacy interests asserted; (5) the possibility of prejudice to those opposing
…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.1
8 pg
…accused to make any statement;
(3) The performance of any examinations or tests or the accused’s refusal or failure to
submit to an examination or test;
(4) The identity, testimony or credibility of prospective witnesses, except that the lawyer…
giuffre-maxwell
gov.uscourts.nysd.447706.1254.0
18 pg
…access to the materials; (2), identify and evaluate the
14 weight of any countervailing interests; and (3) determine
15 whether the countervailing interests rebut the presumption.
16 The presumption of public access attaches to judicial
17 documents, those documents filed…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.11
15 pg
…another purpose, such as proving motive, opportunity, intent, preparation, plan,
knowledge, identity, absence of mistake, or lack of accident.”). Indeed, even more specifically
than the general provisions of Rule 404(b), Rule 415 makes these other acts admissible, due to…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…they’ll 363-11
have to makeFiled
a claim08/11/16
that it was casePage
…
giuffre-maxwell
gov.uscourts.nysd.447706.1100.1
13 pg
…15-cv-07433-LAP
1:20-cr-00330-AJNDocument
Document1100-1
36 Filed
Filed
07/30/20
08/10/20Page
…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…Therefore, Ms. Giuffre is now required to take the deposition of pilot Dave
Rodgers to authenticate his pilot logs and the identity of the individuals on various flights.
In addition, as the Court knows, this case involves allegations that Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.13_1
19 pg
…providers
and produced some of their records. Essentially, Plaintiff argues that her failure to identify her
1
In her own flagrant attempt to direct attention away from sanctionable litigation tactics, Plaintiff includes
in her “Introduction” and her “Conclusion” inaccurate, incomplete…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…commenting on, regarding, discussing, showing,
describing, reflecting, analyzing or constituting.
9. "Identify" means, with respect to any ''person," or any reference to tbe '' identjty"
of any '·person," to provide the name, home address, telephone number, business name, business
address, business…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…Of course, such a redaction does Ms. Giuffre little good when
Defendant and her cohorts distribute it to the press - the identity of the victim in the police report
will presumably be supplied by Defendant. Indeed, Defendant and/or her…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…Therefore, Ms. Giuffre is now required to take the deposition of pilot Dave
Rodgers to authenticate his pilot logs and the identity of the individuals on various flights.
In addition, as the Court knows, this case involves allegations that Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1284.0
17 pg
…15-cv-07433-LAP Document 1284 Filed 12/02/22 Page 3 of 17 3
1 materials; (2) identify and evaluate the weight of any
2 countervailing interests; and (3) determine whether the
3 countervailing interests rebut the presumption.
4 …
giuffre-maxwell
gov.uscourts.nysd.447706.1201.20
21 pg
…nature , custody ,
condition, and location of any documents or other tangib l e
things and the identity and location of persons who know of
any discoverable matter . For good cause , the court may
order discovery of any matter relevant to…
giuffre-maxwell
gov.uscourts.nysd.447706.1283.0
17 pg
…15-cv-07433-LAP Document 1283 Filed 12/02/22 Page 3 of 17 3
1 materials; (2) identify and evaluate the weight of any
2 countervailing interests; and (3) determine whether the
3 countervailing interests rebut the presumption.
4 …
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…23.1(d)(4) (release of the “identity,
testimony or credibility of prospective witnesses” “presumptively involve a substantial
likelihood that their public dissemination will interfere with a fair trial or otherwise prejudice the
due administration of justice”).
Defendant’s proposal…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.24
16 pg
…another purpose, such as proving motive, opportunity, intent, preparation, plan,
knowledge, identity, absence of mistake, or lack of accident.”). Indeed, even more specifically
than the general provisions of Rule 404(b), Rule 415 makes these other acts admissible, due to…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.17_1
16 pg
…another purpose, such as proving motive, opportunity, intent, preparation, plan,
knowledge, identity, absence of mistake, or lack of accident.”). Indeed, even more specifically
than the general provisions of Rule 404(b), Rule 415 makes these other acts admissible, due to…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
… . : 1-05-000368 (Continued)
the previous houseman left . Rodriguez stated that it was his
responsibility to keep the identity of the masseuses private. Mr.
Epstein had a massage in the morning and one in the afternoon. Mr.
Rodriguez stated he…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.27
15 pg
…another purpose, such as proving motive, opportunity, intent, preparation, plan,
knowledge, identity, absence of mistake, or lack of accident.”). Indeed, even more specifically
than the general provisions of Rule 404(b), Rule 415 makes these other acts admissible, due to…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…Of course, such a redaction does Ms. Giuffre little good when
Defendant and her cohorts distribute it to the press - the identity of the victim in the police report
will presumably be supplied by Defendant. Indeed, Defendant and/or her…