giuffre-maxwell
gov.uscourts.nysd.447706.46.0
22 pg
…Civ. P. 44.1
(permitting Court to consider “any relevant material or source” to determine issue of foreign
law).
4
Without waiver of the choice-of-law issue, Ms. Maxwell submits that the privilege also
applies to her communications…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…it is well-recognized that the non-moving party faced with a summary judgment
motion supported by appropriate proof may not rely on bare, conclusory assertions found in the
pleadings to create an issue and thus avoid summary judgment. Instead…
giuffre-maxwell
gov.uscourts.nysd.447706.503.0
21 pg
…the
backgrounds of . co-authors and the [publication's]
editorial staff, and whether [the author] consulted with any
experts or other sources in the course of the investigation-all
inquiries into the newsgathering process protected by the Shield
Law." Baker, …
giuffre-maxwell
gov.uscourts.nysd.447706.849.0
94 pg
…04/12/17 Page 15 of 94 15
H3u1giua
1 redacted, we have no idea who the author of the report is.
2 THE COURT: What's the provenance of this report that
3 we're talking about?
4 MS…
giuffre-maxwell
gov.uscourts.nysd.447706.847.0
94 pg
…04/12/17 Page 15 of 94 15
H3u1giua
1 redacted, we have no idea who the author of the report is.
2 THE COURT: What's the provenance of this report that
3 we're talking about?
4 MS…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.13
15 pg
…made calls and interviewed
particular sources, techniques for the reporters’ investigation, and the backgrounds of the co-
authors and editorial staff).
3
See generally Beth Winegarner, 5 tips for journalists who want to do a better job of cultivating sources…
giuffre-maxwell
gov.uscourts.nysd.447706.363.13
15 pg
…made calls and interviewed
particular sources, techniques for the reporters’ investigation, and the backgrounds of the co-
authors and editorial staff).
3
See generally Beth Winegarner, 5 tips for journalists who want to do a better job of cultivating sources…
giuffre-maxwell
gov.uscourts.nysd.447706.263.0
14 pg
…made calls and interviewed
particular sources, techniques for the reporters’ investigation, and the backgrounds of the co-
authors and editorial staff).
3
See generally Beth Winegarner, 5 tips for journalists who want to do a better job of cultivating sources…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…is a gentleman
17 by the name of Stan Pottinger. He is a lawyer of some renown.
18 He is also an author of best-selling books. He is listed quite
19 frequently on plaintiff's privilege log as being…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.40
30 pg
…is a gentleman
17 by the name of Stan Pottinger. He is a lawyer of some renown.
18 He is also an author of best-selling books. He is listed quite
19 frequently on plaintiff's privilege log as being…
giuffre-maxwell
gov.uscourts.nysd.447706.235.1
31 pg
…is a gentleman
17 by the name of Stan Pottinger. He is a lawyer of some renown.
18 He is also an author of best-selling books. He is listed quite
19 frequently on plaintiff's privilege log as being…
giuffre-maxwell
gov.uscourts.nysd.447706.136.0_2
29 pg
…is a gentleman
17 by the name of Stan Pottinger. He is a lawyer of some renown.
18 He is also an author of best-selling books. He is listed quite
19 frequently on plaintiff's privilege log as being…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.24
4 pg
…prostitute Filed
| News 07/15/21 Page 2 of 4Page 1 of 3
- Home
Alan Dershowitz: 'Sex slave' accuser is serial liar, prostitute
Famed attorney slams woman who claims he had underaged sex with her
A…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.30
4 pg
…prostitute Filed
| News 07/15/21 Page 2 of 4Page 1 of 3
- Home
Alan Dershowitz: 'Sex slave' accuser is serial liar, prostitute
Famed attorney slams woman who claims he had underaged sex with her
A…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.41
4 pg
…prostitute Filed
| News 07/15/21 Page 2 of 4Page 1 of 3
- Home
Alan Dershowitz: 'Sex slave' accuser is serial liar, prostitute
Famed attorney slams woman who claims he had underaged sex with her
A…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.19
4 pg
…Filed
| News 01/05/24 Page 2 of 4Page 1 of 3
- Home
.com
Alan Dershowitz: 'Sex slave' accuser is serial liar, prostitute
Famed attorney slams woman who claims he had underage…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.3_2
12 pg
…10
25 https://www.msn.com/en-us/news/crime/why-ghislaine-maxwell-was-just-as-much-a-predator-as-jeffrey-epstein-author/ar-BB1aNWEb
26 https://www.today.com/video/ghislaine-maxwell-deposition-gives-insight-into-epstein-relationship-94465093962…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…Alan M. Dershowitz, the highly regarded Harvard Law
professor, criminal defense lawyer, and author, is entitled to enjoy the reputation for strict
personal rectitude that he has earned. Unfortunately, however, over the course of the last year
and a half…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.36
10 pg
…302877.html
(last visited February 17, 2017). He is the subject of a recently released book by best-selling author
James Patterson titled Filthy Rich: A Powerful Billionaire, the Sex Scandal that Undid Him, and All
the Justice that Money…
giuffre-maxwell
gov.uscourts.nysd.447706.42.0
7 pg
…a
privilege log entry. Local Civil Rule 26.2 requires that for written communications, a
privilege log should include the author of the document, the addressees of the document,
and any other recipients and “where not apparent, the relationship of…
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