giuffre-maxwell
gov.uscourts.nysd.447706.1078.1
8 pg
…which a reasonable person would
expect to be disseminated by means of public communication, in
connection with pending or imminent criminal litigation with
which they are associated, if there is a substantial likelihood that
such dissemination will interfere with a…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.17
6 pg
…surnames is too broad a request or overly burdensome, particularly, as you have not presented any numbers of
documents associated with those names, since you have not yet run the terms. Should one of the names
somehow yield thousands of…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.2
13 pg
…other accounts at
mindspring.com); (3) any of Ms. Maxwell's email account associated with The Terramar Project
(including any account ending [email protected]); and (4) any other email accounts
either used in the past, or currently in use.
…
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.447706.1161.0_1
17 pg
…groups, “attorneys actively working on this case” and “persons
2
Case 1:15-cv-07433-LAP Document 1161 Filed 11/25/20 Page 3 of 17
regularly employed or associated with the attorneys actively
working on this case,” (id…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.13
13 pg
…not limited to the following: (1) (and any
and any other accounts at
(3) any of Ms. Maxwell's email account associated with The Terramar Project
(including any accoun …
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.447706.956.0
3 pg
…press. We believe that these materials, which repeat
provably-false and defamatory allegations of sexual misconduct against Mr. Dershowitz, were
leaked by persons associated with Virginia Roberts Giuffre (“Ms. Roberts”), the plaintiff in the
above-captioned matter. Once again, Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…of all persons involved in the Communication, including the
identity of the law enforcement agency with whom the agent is or was
affiliated;
d. the case number associated with any such Communication;
e. the subject matter of any such Communication;
…
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.447706.1218.49
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.447706.1305.0
4 pg
…its discretion in ordering the unsealing of certain litigation
materials that identify Doe 171. In “announc[ing] its rulings on the unsealing of documents
associated” with Doe 171, the District Court stated that its “findings are a result of [its…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…s
Counsel
Release
Provided
Wellington
to 04/29/16 Sent via e-mail signed release
Imaging
Defendan to Menninger (obtain records directly).
<…
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.447706.1073.0
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1240.0
5 pg
…2018)
(finding that non-parties’ “desire not to be associated with this lawsuit” is not a sufficient privacy
justification to warrant redacting their names).
Any privacy interests that the Does may have are substantially outweighed by the public
interest in…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…not already
responded to either at her first deposition or during this deposition, Ms. Maxwell requests that
the fees and costs associated with defending this Motion be imposed on Plaintiff, her counsel or
both.
Respectfully submitted,
…
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