giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…363-11 Filed 08/11/16 Page 2 of 40
MENU
ALAN DERSHOWITZ, DEFAMATION, LAW PROFESSORS
Settlement Reached In Litigation Between
Alan Dershowitz, Paul Cassell, And Bradley
Edwards
By DAVID LAT
6 Comments / 32 Shares / Apr 8…
giuffre-maxwell
gov.uscourts.nysd.447706.1312.0
9 pg
…certain documents might be embarrassing, would expose non-
parties to media attention, and could result in some unfortunate association between the non-parties
and Jeffrey Epstein or Ghislaine Maxwell. But as the Court has previously recognized, such
generalized concerns about…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.35
7 pg
…and where the following proceedings were
reported by:
Michele Cameron
Magna Legal Services
866-624-6221
Case 1:15-cv-07433-LAP Document 1218-35 Filed 07/15/21 Page 3 of 7
Page 23
…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.31
2 pg
…Opposition to Defendant’s Motion To Reopen Plaintiff’s Deposition.
2. Attached as Exhibit D (filed under seal) is a true and correct copy of
correspondence between Plaintiff and literary agent Marianne Strong dated February 19, 2014
and February 21…
giuffre-maxwell
gov.uscourts.nysd.447706.422.0
8 pg
…R. Civ. P. 37(a)(3),
files this Renewed Motion to Compel Settlement Agreement regarding the confidential
settlement agreement between Plaintiff and Jeffery Epstein, and states as follows:
INTRODUCTION
As part of her scorched earth litigation practice, Plaintiff, without any…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…Jeffrey Epstein, is named as a party.
DOC 291 merits specific discussion. DOC 291 thoroughly outlines: (1) The relationship
between Dershowitz and Epstein; (2) Dershowitz's role representing Epstein during the criminal
investigation of Epstein; (3) Dershowitz's role in…
giuffre-maxwell
gov.uscourts.nysd.447706.1118.0
21 pg
…and for Confidential Access to Judicial Records and Discovery Documents (“Motion”) and states
as follows:
INTRODUCTION
The Government seeks to intervene in this five-year old, closed civil defamation action
between two private civil litigants, Plaintiff Giuffre and Defendant Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.961.0
9 pg
…of course, to immediately implement the destruction provisions in that
order. But counsel are now torn between two courts. Three appeals are currently pending in the
Second Circuit regarding the protective order, and appellants in several of the appeals have…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…private boat or helicopter, with no public or commercial
transportation servicing the island. Id. Flight logs show that between 2001 and 2019, girls and
young women were transported to the Virgin Islands and then helicoptered to Little St. James.
Id., …
giuffre-maxwell
gov.uscourts.nysd.447706.1295.12
4 pg
…deposition of Sarah Ransome on February 17, 2017, designated Confidential under the
Protective Order.
4. Attached as as Exhibit C (filed under seal) is a true and correct copy of the
engagement letter between Ms. Ransome and Farmer, Jaffe, Weissing…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.18
3 pg
…2016 deposition of Ghislaine Maxwell, designated Confidential under the
Protective Order.
3. Attached as Exhibit B (filed under seal) are true and correct copies of
communication between Mr. Gow and Ms. Maxwell Bates stamped GM_01036-01044.
Case 1…
giuffre-maxwell
gov.uscourts.nysd.447706.66.0_1
35 pg
…say this. If you have a meet and confer,
24 I would like to have correspondence between the parties as to
25 what the subject is so that there is an agreed agenda that's
SOUTHERN DISTRICT REPORTERS, P.C…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.42
5 pg
… Do you have the originals?
2 A. Again, between the FBI and giving them to
3 my lawyers and Sharon Churcher, the circulation, I'm not
4 too sure if I have the originals. I know I have copies.
5…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…the subpoena served on Ms. Ransome seeks documents that are wholly
irrelevant to the underlying action including protected financial information and documents or
communications between Sarah Ransome and her attorneys, which are protected by the attorney-
client privilege and the…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.1_1
7 pg
…piece by
11 piece who -- I know Glenn Dubin was first.
12 Q Okay.
13 A And I know Stephen Kaufmann was one of the
14 first I was sent to. Alan Dershowitz could have been
15 between there. Between…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…the subpoena served on Ms. Ransome seeks documents that are wholly
irrelevant to the underlying action including protected financial information and documents or
communications between Sarah Ransome and her attorneys, which are protected by the attorney-
client privilege and the…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.7
11 pg
…there was a
13 request and it appears to be in agreement to
14 allow.
15 MR. SCOTT: No agreement.
16 SPECIAL MASTER: Hang on one second. Hang
17 on. Between Mr. Scarola and Ms. McCawley, to
18 allow Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.39
36 pg
…say this. If you have a meet and confer,
24 I would like to have correspondence between the parties as to
25 what the subject is so that there is an agreed agenda that's
SOUTHERN DISTRICT REPORTERS, P.C…
giuffre-maxwell
gov.uscourts.nysd.447706.1025.0
17 pg
…Order and Protocol Governing the Excerpts (“Non-
Party Request”);
• Form – Non-Party’s Objection to Unsealing (“Non-Party Objection”).
The original parties have conferred between themselves and with counsel for
Intervenors Brown and Miami Herald and for J. Doe (collectively…
giuffre-maxwell
gov.uscourts.nysd.447706.149.0
9 pg
…wit, that Ms. Maxwell “assisted” and participated in
sexual abuse of the Plaintiff between 1999 and 2002.
Plaintiff does not claim that any sexual abuse occurred after 2002 or that she had any
contact with Ms. Maxwell after 2002. Indeed…
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