giuffre-maxwell
gov.uscourts.nysd.447706.1059.0
3 pg
…Doc.892, at 4-10. It found that “the
parties and multiple deponents have reasonably relied on the Protective Order in giving
testimony and producing documents including evidence of assault, medical records, and
emails,” and “[t]hird-party witnesses have…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…in filing a legal document on
their client's behalf which contained those allegations. As a result, the undisputed record
evidence establishes that Dershowitz waged a baseless international media assault on the
honesty, integrity, and professionalism of Edwards and Cassell…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.40
19 pg
…Joshua Bunner
Address unknown at this time
Joshua Bunner has knowledge concerning Plaintiff’s credibility, including false
claims of sexual assault.
13. Carolyn Casey
Address unknown at this time
Telephone number unknown at this time
3
Case 1:15-cv…
giuffre-maxwell
gov.uscourts.nysd.447706.515.0
12 pg
…lodge defamation claims against them. Indeed, just three weeks earlier, an accuser of Bill Cosby filed for defamation
based his then recent denials of a 2005 sexual assault. See CBS News, “Bill Cosby Hit with a Defamation Lawsuit,”
(Dec. 10…
giuffre-maxwell
1320-40
19 pg
…Joshua Bunner
Address unknown at this time
Joshua Bunner has knowledge concerning Plaintiff’s credibility, including false
claims of sexual assault.
13. Carolyn Casey
Address unknown at this time
Telephone number unknown at this time
3
Case 1:15-cv…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.11
13 pg
…RFP No. 1 seeks documents Mr. Pagliuca allegedly ‘reviewed and/or relied upon’ in
allegedly making statements stating that Plaintiff previously made false accusations of sexual
assault.” (Br. at 5). (Emphasis original).
How Defendant purports to distinguish between the actual…
giuffre-maxwell
gov.uscourts.nysd.447706.949.0
31 pg
…names and
16 substituting initials and things like that. They don't
17 identify the names of victims of sexual assaults.
18 But the law is such that we have to decide what
19 standard applies. But in any event…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…the discovery sought from the Maxwell case is believed
to be particularly relevant to Dershowitz’s defense of the sexual assault claims which Giuffre has
brought against him on the theory that he was “on notice” that she was being…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…Rather, on the way to the detox unit at the hospital, Plaintiff
claimed she had been forcibly sexually assaulted by her friends. Plaintiff’s claim
of forced sexual assault was expressly refuted by the witnesses, who also verified
Plaintiff’s…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…reasonably
required to respond to the instant motion, and while it surely has the distinct air of “protesting
too much,” I cannot stand mute in the face of this continuing assault on my character. As this
declaration and the accompanying…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…the plaintiff in this lawsuit, and
republished all over the world. Professor Dershowitz has done everything in his power to
combat this assault on his reputation, from proclaiming his innocence in public, to marshalling
every bit of information within his…
giuffre-maxwell
gov.uscourts.nysd.447706.1284.0
17 pg
…is
11 denied. On the consent of the plaintiff and in light of Doe
12 28's status as a victim of sexual assault who continues to
13 experience trauma as a result of these events, Doe 28's name…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.8
12 pg
…refused to comply with a deposition subpoena in an earlier case
8
Case 1:15-cv-07433-LAP Document 1320-8 Filed 01/03/24 Page 9 of 12
brought by one of Jeffrey Epstein’s sexual assault victims…
giuffre-maxwell
gov.uscourts.nysd.447706.1283.0
17 pg
…is
11 denied. On the consent of the plaintiff and in light of Doe
12 28's status as a victim of sexual assault who continues to
13 experience trauma as a result of these events, Doe 28's name…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.4_1
29 pg
…Cassell alleged that
“[i]mmediately following the filing of what Dershowitz knew to be an entirely proper and well-
founded pleading, Dershowitz initiated a massive public media assault on the reputation and
character of Bradley J. Edwards and Paul G…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…COURT: Yes.
9 MS. McCAWLEY: Sorry. So with respect to the reason
10 why individuals who may have been victims of sexual assault
11 would be confidential, there is case law that we cite in our
12 brief, Doby v…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.24
16 pg
…offers no explanation for her convenient
forgetfulness. Moreover, evidence of being recruited by Defendant and being sexually assaulted
is not something Ms. Giuffre can obtain through requests for production or through
interrogatories. The only way of obtaining such evidence is…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.17_1
16 pg
…offers no explanation for her convenient
forgetfulness. Moreover, evidence of being recrnited by Defendant and being sexually assaulted
is not something Ms. Giuffre can obtain through requests for production or through
intenogatories. The only way of obtaining such evidence is…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.27
15 pg
…offers no explanation for her convenient
forgetfulness. Moreover, evidence of being recruited by Defendant and being sexually assaulted
is not something Ms. Giuffre can obtain through requests for production or through
interrogatories. The only way of obtaining such evidence is…
giuffre-maxwell
gov.uscourts.nysd.447706.1067.0
10 pg
…Sexual content alone is insufficient to justify continued sealing of Ms. Maxwell’s
deposition transcript. This case concerns allegations of sexual assault and trafficking of
minors. There is no recognized privacy interest in allegations of sex trafficking. Any
privacy interest…