giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
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.447706.1248.0
6 pg
…other. As discussed in more detail below, the former group can maintain privacy by narrowly
redacting information that would identify those who have not previously been publicly identified
1
As with prior filings, counsel for Intervenors have seen only Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.18_2
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.447706.1219.43
12 pg
…what the Defendant could have said in her response – but did not say. Defendant
could have said that she used an email account from 1999-2002 and could have provided the
identity of the account. She did not say that…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
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.447706.1137.1_1_1_1
10 pg
…consensual adult sex" and no need be given. The result is
to leave Ms. Giuffre with no way of exploring the identity of these alleged adults, the ages of
these alleged adults, and indeed whether they were adults at all…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.3
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.447706.1137.16_2
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.447706.1331.16
10 pg
…different.
The cases were personal claims against Mr. Epstein by various individuals. There could be no
identity of issues between those matters and this case. Those cases were about personal claims
against Mr. Epstein and had nothing to do with…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.9
21 pg
…nature, custody,
condition, and location of any documents or other tangible
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 the subject…
giuffre-maxwell
gov.uscourts.nysd.447706.1083.0
3 pg
…late on July 29 numerous
proposed redactions which disregard the Court’s Order to redact “names of nonparties” and
“nonparties’ specific conduct.” Plaintiff proposes to unseal significant portions of the
testimony which would not only identify the Nonparty at issue…
giuffre-maxwell
gov.uscourts.nysd.447706.143.0
10 pg
…consensual adult sex” and no need be given. The result is
to leave Ms. Giuffre with no way of exploring the identity of these alleged adults, the ages of
these alleged adults, and indeed whether they were adults at all…
giuffre-maxwell
gov.uscourts.nysd.447706.230.0
19 pg
…1
I. PLAINTIFF’S PRODUCTION OF KEY DOCUMENTS AFTER HER DEPOSITION
NECESSITATES ADDITIONAL EXAMINATION ............................................................. 3
A. Plaintiff failed to identify her health care providers and produce their records prior to
her deposition, despite this Court’s or…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.21
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.447706.1113.0
7 pg
…modification
2 That sealed order excludes from production to Mr. Dershowitz
material produced by or material (or portions of material) that
discusses a specific nonparty Doe whose identity will remain
confidential. With respect to material not produced by the
nonparty…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.15
14 pg
…2
I. PLAINTIFF’S PRODUCTION OF KEY DOCUMENTS AFTER HER DEPOSITION
NECESSITATES ADDITIONAL EXAMINATION ............................................................. 2
A. Plaintiff failed to identify her health care providers and produce their records prior to
her deposition, despite this Court’s order …
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…4
Case 1:15-cv-07433-RWS Document 17-1 Filed 12/01/15 Page 5 of 13
8. “Identify” means, with respect to any “person,” or any reference to the “identity”
of any “person,” to provide the name…
giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…under Rule 26.3(c)(7), Southern District of New York Local Civil Rules.
8. “Identify” (with respect to persons) incorporates the definition as set forth in Rule
26.3(c)(3), Southern District of New York Local Rules. Therefore…
giuffre-maxwell
gov.uscourts.nysd.447706.1100.0
16 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.447706.1325.7
30 pg
…Ms. Giuffre gave to Defendants in
her interrogatories (Mtn. at 3), but then states that “Plaintiff failed therein to identify any
treatment providers prior to the alleged defamation, despite the Court’s order concerning 1999-
2015.” (Mtn. at 4). This…