giuffre-maxwell
gov.uscourts.nysd.447706.1196.0
32 pg
…Ms. Maxwell from Haddon Morgan and
13 Foreman.
14 THE COURT: Good morning.
15 Counsel, as you know, today the Court announces its
16 rulings on the unsealing of the motions associated with docket
17 entries 231, 279, 315, 320…
giuffre-maxwell
gov.uscourts.nysd.447706.1099.0
4 pg
…and 659. Maxwell’s counsel rejected that
proposal based on the volume of documents and pages associated with those motions, and
suggested considering only five more motions in the next round of unsealing without specifying
which five motions she contended…
giuffre-maxwell
gov.uscourts.nysd.447706.1220.0
17 pg
…MCCAWLEY: Good morning, your Honor.
4 THE COURT: All right. May we begin, my friends.
5 Today, the Court announces its rulings on the
6 unsealing of the motions associated with docket entries 345,
7 356, 362, 370, 422, 468…
giuffre-maxwell
gov.uscourts.nysd.447706.1284.0
17 pg
…22 Page 2 of 17 2
1 THE COURT: As we all know, this is Giuffre against
2 Maxwell. Today the Court announces its rulings on the
3 unsealing of documents associated with nonparty Does 12, 28,
4 97, 107…
giuffre-maxwell
gov.uscourts.nysd.447706.1283.0
17 pg
…22 Page 2 of 17 2
1 THE COURT: As we all know, this is Giuffre against
2 Maxwell. Today the Court announces its rulings on the
3 unsealing of documents associated with nonparty Does 12, 28,
4 97, 107…
giuffre-maxwell
gov.uscourts.nysd.447706.503.0
21 pg
…she was employed as the New
York-based Chief American Correspondent of The Mail on Sunday, a
publication owned by Associated Newspapers of London, England.
During the interim she worked as a freelance reporter for
publications including The Mail on…
giuffre-maxwell
gov.uscourts.nysd.447706.41.5
18 pg
…RWS Document 41-5 Filed 03/04/16 Page 4 of 18
b. persons regularly employed or associated with the attorneys actively
working on this case whose assistance is required by said attorneys in the
preparation for trial, at trial…
giuffre-maxwell
gov.uscourts.nysd.447706.1079.0
4 pg
…Indeed, in her original
objection to unsealing, Ms. Maxwell argued that the specter of
ongoing criminal investigations into unknown individuals
associated with Jeffrey Epstein--a group that, of course, includes
Ms. Maxwell--loomed large over the Court-ordered unsealing
1…
giuffre-maxwell
gov.uscourts.nysd.447706.39.1
7 pg
…attorneys actively working on this case;
b. persons regularly employed or associated with the attorneys actively
working on this case whose assistance is required by said attorneys in the
preparation for trial, at trial, or at other proceedings in this…
giuffre-maxwell
gov.uscourts.nysd.447706.751.9
3 pg
…damages," the former
Harvard Law professor said. "I welcome that lawsuit. I welcome any opportunity that would put her under oath and
require her to state under oath these false allegations."
The Associated Press contributed to this report.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…at issue “would be detrimental to [Doe 28’s] wellbeing as [they were] a sexual
abuse victim of Jeffrey Epstein, who is deceased and a non-party but associated with the Defendant
in this case.” Doe 28 Obj. at 2…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…paying Ms. Maxwell’s legal fees. Plaintiff sought by way of
discovery any “contracts,” “indemnification agreements,” “employment agreements”
between Ms. Maxwell and Epstein or any entity associated with Epstein, from 1999 to the
present. Ms. Maxwell responded under oath that…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…Case
Numerous Publicly Available Police Reports With Redacted Juvenile
Information
In complete contradiction to her legal position in this Motion, Plaintiff and her counsel
have repeatedly filed in public documents associated with this case, police reports from Florida
…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.18
11 pg
… Case 1:15-cv-07433-LAP Document 1090-18 Filed 07/30/20 Page 10 of 11
associated with attending any deposition occurring outside 100 miles of the Courthouse for the
Southern District of New York pursuant to S…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…civil complaint against Mr. Epstein on Ms. Giuffre’s behalf which accused “academicians”
3
Case 1:15-cv-07433-LAP Document 1218-49 Filed 07/15/21 Page 4 of 27
associated with Mr. Epstein of abusing her; (iv…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…to an inference in her favor when a witness takes the
Fifth Amendment rather than answer a relevant question where that witness is associated with the other side of the
case or otherwise in an adverse position to the victims…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…Ms. Giuffre submitted to interviews with law
enforcement, told her story to the media, drafted a tell-all memoir, and filed a lawsuit alleging
that Mr. Epstein had trafficked her to many of his prominent associates. Id. ¶¶ 10-14. During…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…as I said, is a telephone directory
16 of all the names and numbers of anybody who was associated with
17 either the defendant or Maxwell -- of the defendant or Epstein.
18 It was kept at their home; they had…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…01/05/24 Page 16 of 17
Adverse Inference Instruction, and 2) for attorneys’ fees and costs associated with responding to
this Motion pursuant to 37(a)(5)(B), and such other and further relief as this Court deems just.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…DE 143 and Related Pleadings
Docket Entry 143 and its associated pleadings involve Plaintiff’s effort
which were not and should not
have been relevant to Plaintiff’s false claim that she was sexually abused by Epstein as a minor…
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