giuffre-maxwell
gov.uscourts.nysd.447706.936.0
21 pg
…reasons. Instead, the Parties benefited from a presumption of closure.
Of particular importance, a main reason denying the prior motions to unseal – the on-going
status of the litigation – is no longer relevant because the litigation has been settled. While…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.16
22 pg
…alleged personal assistant.
Defendants Epstein and Maxwell continuously and frequently demanded that
Plaintiff fulflll this task as a condition of her receiving the education, career and
related benefits promised by Defendants Epstein and Morwell. Based upon
Plaintiffs experience with Defendants…
giuffre-maxwell
gov.uscourts.nysd.447706.165.1
6 pg
…to any party’s claim or defense, are
not proportional to the needs of the case, and creates a heavy
burden on…
giuffre-maxwell
gov.uscourts.nysd.447706.156.7
6 pg
…are not relevant
to any party’s claim or defense, are not
proportional to the needs of the case, and creates
…
giuffre-maxwell
gov.uscourts.nysd.447706.1125.0_2
5 pg
…decision
by the Court to undercut that purpose. Should Does 1 and 2 wish
to submit a more thorough explanation for their objection, doing
so would be to the benefit of all involved in this process.
Third, and relatedly, that …
giuffre-maxwell
gov.uscourts.nysd.447706.1330.17
12 pg
…whether the party
requesting the deposition has had other opportunities to obtain the same information, and
whether the burden of a second deposition outweighs its potential benefit.’” Id. (quoting Ganci,
1
Case 1:15-cv-07433-LAP Document 1330…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…not proportional to the
needs of the case. Such requests would create a heavy burden on Ms. Giuffre that outweighs any
benefit. Such discovery is prohibited by the Federal Rules of Civil Procedure, particularly under
the 2015 amendments to Rule…
giuffre-maxwell
gov.uscourts.nysd.447706.1006.0
1 pg
…Therefore, the Court
can have the benefit of whichever format it prefers to work from. Plaintiff’s format includes the
specifics of sealed orders and details of the sealed exhibits for ease of the Court’s reference and
accordingly is…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.38
8 pg
…on privilege, he wagered that the consequences from this Court for his deliberate violation
of the settlement privilege would not be harsh enough to offset the benefit he received by feed ing
fa lse information to the press. On December…
giuffre-maxwell
gov.uscourts.nysd.447706.639.0
2 pg
…455 at 2.
In the interests of judicial economy, the parties believe it would be appropriate to
have the benefit of the Court's rulings on these other issues, review the designated
testimony in light of such rulings and then…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.29_1
16 pg
…not proportional to the
needs of the case. Such requests would create a heavy burden on Ms. Giuffre that outweighs any
benefit. Such discovery is prohibited by the Federal Rules of Civil Procedure, particularly under
the 2015 amendments to Rule…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.12
10 pg
…Simply
put, she should not be allowed to benefit from her obvious failure to properly disclose Ms.
Ransome.
Ms. Ransome's Testimonv is ot Cumulative And Has Highly Relevant Evidence
Defendant also advances the remarkable argument that it is "unlikely…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.37
9 pg
…for his deliberate violation of the
settlement privilege will not be harsh enough to offset the benefit he received by feeding false
Case 1:15-cv-07433-LAP Document 1218-37 Filed 07/15/21 Page 3 of 9
…
giuffre-maxwell
gov.uscourts.nysd.447706.1045.0
2 pg
…it references J. Doe 1 or 2, so that the Court has the benefit of the
“Related Docket #” column listing the related filings.
Ms. Maxwell submits that consideration of the motions in chronological order is the
most logical, efficient and…
giuffre-maxwell
gov.uscourts.nysd.447706.441.0
18 pg
…in resolvingthe issu es,and whetherthe bu rd en orex pense of the proposed
d iscovery ou tweighs its likely benefit.
Ru le 26(b)(1),Fed .R.C iv.P .D efend ant’s d iscovery requ ests foremploymentand…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…or defense; and documents that are not proportional to the needs of the case.
Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such discovery
is prohibited by the Federal Rules of Civil Procedure, particularly under…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…he had no role in issuance of the statement, he has
no benefit in the outcome of this litigation and he played no controlling role in its respect.
Similarly, there is not any evidence at all to support an adverse…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…fundamentally unfair to
allow Giuffre to continue to press these allegations where she and her attorneys have had the full
benefit of discovery already conducted concerning these allegations which is in her possession and
which is being withheld Dershowitz and…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…Inc., 285 B.R. 101, 109
(E.D.N.Y. 2002) (quoting United States v. Peoples Benefit Life Ins. Co., 271 F.3d 411, 415 (2d
Cir. 2001)).
Under Rule 24(b), courts in this Circuit consider the following factors…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…Numerous depositions have already been taken by Ms. Giuffre without the
benefit of these documents. The window for authenticating the documents through depositions
7
Case 1:15-cv-07433-LAP Document 1332-1 Filed 01/08/24 Page 9…
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