giuffre-maxwell
gov.uscourts.nysd.447706.1295.14
6 pg
…at Dalton, where
detoils obout the police he tutored the son of a Bear Stearns exec. Soon, Epstein applied his facility with numbers on Wall Street
investigotion ond o lot but left Bear Stearns under a cloud in 1981. He…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.10
23 pg
…and the court
24 specifically indicated that sexual
25 activity of third parties who bear no
MAGNA·9 LEGAL SERVICES
Case 1:15-cv-07433-LAP Document 1328-10 Filed 01/05/24 Page 4 of 23
Confidential
Page 2…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.10
23 pg
…and the court
24 specifically indicated that sexual
25 activity of third parties who bear no
MAGNA9 LEGAL SERVICES
Case 1:15-cv-07433-LAP Document 1327-10 Filed 01/05/24 Page 4 of 23
Confidential
Page 2 0…
giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…Accordingly, the Non-Party objectors bear the burden of identifying with specificity
2
Case 1:15-cv-07433-LAP Document 1247 Filed 03/18/22 Page 7 of 25
countervailing interests that outweigh the presumption of public access. See…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.42
9 pg
…to me,
and my siblings, and our kids and that was pop's love, like a big bear hug on your
heart kind of love. His unique sense of humor could be a weapon and a salve.
M. CUOMO: Christopher…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…produce documents, Ms. Giuffre has
produced a number of documents including turning over personal, embarrassing documents that
bear no relation to the claim at issue in this case. Indeed, Defendant has procured other
documents with the same issues, including those…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.35
10 pg
…enforcement.
ARGUMENT
None of these factual assertions bear on the issue before the Court -- whether Plaintiff’s
publicly available criminal files should be deemed “confidential” under the Protective Order.
None of the witnesses has anything to do with Plaintiff’s…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…time period, though Defendant need not answer questions that relate to none of these
subjects or that is clearly not relevant, such as sexual activity of third-parties who bear no
knowledge or relation to the key events, individuals, or…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.16
30 pg
…part of her next production, so that they would bear a Bates label for tracking
11
Case 1:15-cv-07433-LAP Document 1256-16 Filed 05/03/22 Page 16 of 30
purposes. It was a formality since…
giuffre-maxwell
gov.uscourts.nysd.447706.363.13
15 pg
…and
Maxwell must make a “clear showing” of all of the elements to overcome the protection for non-
1
Defined, capitalized terms bear the same meanings as in Churcher’s Memorandum of Law in Support of the
Motion (Dkt. No…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…evidence to be discoverable. Relevance is still to be “construed
broadly to encompass any matter that bears on, or that reasonably could lead to other matter that
could bear on” any party's claim or defense. State Farm Mut. Auto…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.7
30 pg
…part of her next production, so that they would bear a Bates label for tracking
11
Case 1:15-cv-07433-LAP Document 1325-7 Filed 01/04/24 Page 16 of 30
purposes. It was a formality since…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.19
30 pg
…Ms. Giuffre included those documents that both sides received in the
deposition as part of her next production, so that they would bear a Bates label for tracking
purposes. It was a formality since both sides already had the record…
giuffre-maxwell
gov.uscourts.nysd.447706.55.12
21 pg
…Today is September 8, 2009. 7 around 19 -- please bear with the dates because I
8 The time is 12 minutes after 10:00 in the morning. 8 trying --
9 This is the videotaped deposition of Juan 9 Q. Sure.
…
giuffre-maxwell
gov.uscourts.nysd.447706.263.0
14 pg
…and
Maxwell must make a “clear showing” of all of the elements to overcome the protection for non-
1
Defined, capitalized terms bear the same meanings as in Churcher’s Memorandum of Law in Support of the
Motion (Dkt. No…
giuffre-maxwell
gov.uscourts.nysd.447706.851.0
158 pg
…a few documents upon which these arguments are based.
23 I have four documents that I'm handing up.
24 I have to get a little bit into the weeds here, so
25 please bear with me. In this case…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.14
30 pg
…Ms. Giuffre included those documents that both sides received in the
deposition as part of her next production, so that they would bear a Bates label for tracking
purposes. It was a formality since both sides already had the record…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.7
12 pg
…time period, though Defendant need not answer questions that relate to
none of these subjects or that is clearly not relevant, such as sexual activity of
third-parties who bear no knowledge or relation to the key events, individuals, or…
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