…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…
…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…
…7 Case 1:15-cv-07433-LAP Document 1307-4 Filed 08/25/23 Page 12 of 28 Whether it was a lie for Ms. Giuffre to say that Defendant approached females to bring them to Epstein. Id…
…Ms. Maxwell, a stranger to her, approached her on her college campus, and told her she would hire Ms. Sjoberg as her personal assistant. After Ms. Sjoberg began to work for Defendant inside the home she shared with Epstein, Defendant…
…239. 7 Case 1:15-cv-07433-LAP Document 1137-12 Filed 10/22/20 Page 12 of 28 • Whether it was a lie for Ms. Giuffre to say that Defendant approached females to bring them to Epstein. Id…
…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…
…Ms. Maxwell, a stranger to her, approached her on her college campus, and told her she would hire Ms. Sjoberg as her personal assistant. After Ms. Sjoberg began to work for Defendant inside the home she shared with Epstein, Defendant…
…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…
…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…
…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.…
… If we had planned for this to be a 25 month long case, I think we would have approached this SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 Case 1:15-cv-07433-LAP Document 1332-10 Filed 01…
… If we had planned for this to be a 25 month long case, I think we would have approached this SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 Case 1:15-cv-07433-RWS Document 702 Filed 03/08…
…Lightfoot’s own records, written in 2011, describe Defendant as Ms. Giuffre’s abuser: . . . was approached by Ghislaine Maxwell who said she could help her get a job as a massage therapist . . . seemed respectable . . . was shown how to massage, etc…
…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…
…privacy interests of those resisting disclosure.” Id. at 120. The Second Circuit has established two approaches for determining whether the public and press have a qualified First Amendment right to access certain judicial documents. The “experience and logic” approach requires…
…2016. Ms. Maxwell has twice sat for deposition, approaching 13 hours on the record, far more than the presumptive 7 hour limit under the Federal Rules. During that time, Plaintiff has had a full and fair opportunity to depose Ms…
…As a result, John Doe is in no position to speculate (let alone dictate) how the Court should approach and consider the categories of documents that the parties have agreed upon, to say nothing of offering wholly new categories for…
…Dkt. 279: Motion for Adverse Inference Instruction, Dkt. 345: Motion to Compel Production of Documents Subject to Improper Objection, and Dkt. 659: Second Motion to Compel. To illustrate the utility of this approach, at the March 31, 2020, conference, the…
…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…
…2020 Tr. 4:3-16. Plaintiff contends that Defendant’s approach contravenes the Court’s ruling, which (as did the Second Circuit) unsealed the documents subject to limited redactions. Given the parties’ disagreement, Plaintiff will send her proposed redactions to…
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