giuffre-maxwell
gov.uscourts.nysd.447706.1090.18
11 pg
…as Plaintiff now concedes. It read: “In 1999, Jane Doe #3 was
approached by Ghislaine Maxwell,” and continuing that “Maxwell persuaded Jane Doe # 3 (who was only fifteen
years old) to come to Epstein's mansion . . .” Plaintiff now concedes that…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.2
23 pg
…Page 12 of 23
” That the
government claimed, indicated that the
Nowhere did the government
acknowledge that had in fact approached the prosecutors multiple times well
bef…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…based on this discovery, that she was not 15 years old, she now
has conclusive proof that she was an underage minor when Ghislaine Maxwell approached her,
recruited her, introduced her to Jeffrey Epstein, and sexually trafficked her as an…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…not “was wholly irrelevant” to Boies’s involvement in court.
Separately, Dershowitz took issue with the way he said Boies’ firm approached him after Roberts’ claims
first arose in late 2014. Dershowitz said that one of Boies Schiller’s lawyers…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…the property called 'Tuckedaway' was
'troubling'.
They wrote that when the FBI arrived they were confronted by a locked gate which they
forced their way through.
The filing said: 'As the agents approached the front door to the main house…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…Jane Doe #3
would prove the following:
In 1999, Jane Doe #3 was approached by Ghislaine Maxwell, one of the main women
whom Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator
in his…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.21
19 pg
…to have his friends
go away. He says that he did. ~ l s osays that at this time he was
also approached by his neighbor, who is a real estate agent
and is selling his p a r ~ . …
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…I have
film footage all over Europe itching to be released.” Ex. 1 (RANSOME_000521);
x Her friend was “approached, by Special Agents Forces Men sent directly by Hilary [sic]
Clinton herself, in order to protect her presidential campaign.” Ex…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.20
11 pg
…as Plaintiff now concedes. It read: “In 1999, Jane Doe #3 was
approached by Ghislaine Maxwell,” and continuing that “Maxwell persuaded Jane Doe # 3 (who was only fifteen
years old) to come to Epstein's mansion . . .” Plaintiff now concedes that…
giuffre-maxwell
1320-20
11 pg
…as Plaintiff now concedes. It read: “In 1999, Jane Doe #3 was
approached by Ghislaine Maxwell,” and continuing that “Maxwell persuaded Jane Doe # 3 (who was only fifteen
years old) to come to Epstein's mansion . . .” Plaintiff now concedes that…
giuffre-maxwell
1320-9
10 pg
…Jane Doe #3
would prove the following:
In 1999, Jane Doe #3 was approached by Ghislaine Maxwell, one of the main women
whom Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator
in his…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.7
21 pg
…counsel in this case. According to the Criminal Complaint filed against
Mr. Rodriguez in 2009, Mr. Rodriguez approached one of the lawyers and offered to sell the
lawyer evidence against Mr. Epstein. United States v. Rodriguez, United States District Court…
giuffre-maxwell
gov.uscourts.nysd.447706.189.0
11 pg
…Jane Doe #3 Circumstances is false, . It read: “In 1999, Jane Doe #3 was
approached by Ghislaine Maxwell,” and continuing that “Maxwell persuaded Jane Doe # 3 (who was only fifteen
years old) to come to Epstein's mansion . . .”
. Menninger Decl.…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.3
10 pg
…Jane Doe #3
would prove the following:
In 1999, Jane Doe #3 was approached by Ghislaine Maxwell, one of the main women
whom Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator
in his…
giuffre-maxwell
gov.uscourts.nysd.447706.1005.0
6 pg
…been categorical and succinct. It was neither. The decision turned on the Second Circuit’s
lengthy discussion of the First and Third Circuits’ divergent approaches to the question, when
is a mere document transformed into a judicial one? The Third…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…at 119-20. It is a given
accepted by the Protective Order that the trial and all trial
documents are accessible and public absent special
circumstances.
Under the common law approach, once a document is
classified as a judicial document…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…been categorical and succinct. It was neither. The decision turned on the Second Circuit’s lengthy
discussion of the First and Third Circuits’ divergent approaches to the question, when is a mere
document transformed into a judicial one? The Third…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…The parties in Dershowitz have done just that and have presented a “reasonable”
approach in which Giuffre has no objection to producing certain enumerated categories from
among the Maxwell confidential materials and sealed filings in her possession so long as…
giuffre-maxwell
gov.uscourts.nysd.447706.139.0
7 pg
…here. Indeed, she cannot approach that standard,
as she has made no showing whatsoever of any compelling or particularized need for these
materials. Defendant is attempting to improperly interfere with an ongoing criminal investigation,
and under New York law, disclosure…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.11
9 pg
…2017, followed up on this by presenting argument on the Motion to Compel
that relied almost entirely on the rules-violating reply.
Because of the unfairness from plaintiff’s chaotic approach to motion practice, we
requested on March 9 leave…
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