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.447706.364.0
32 pg
…ARGUMENT .................................................................................................................................11
I. PROFESSOR DERSHOWITZ SHOULD BE PERMITTED TO INTERVENE
UNDER FEDERAL RULE OF CIVIL PROCEDURE 24(B) ..............................11
A. …
giuffre-maxwell
gov.uscourts.nysd.447706.1066.0
1 pg
…SUBSTITUTION OF
GHISLAINE MAXWELL, COUNSEL FOR
INTERVENOR ALAN M.
Defendant. DERSHOWITZ
------------------------------------------------------…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.13
15 pg
…TO SHOW THAT CHURCHER WAS NOT
ENGAGED IN PROTECTED NEWSGATHERING ACTIVITY ........................ 3
A. The “Primary Relationship” Between Churcher and Plaintiff Was
Reporter and Source ...................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.0
1 pg
…15 Civ. 7433 (LAP)
Dear Judge Preska:
Pursuant to the Court Order dated April 19, 2022, Ms. Maxwell hereby files those
documents ordered unsealed between the Dkt. Nos. 321-6 and 631, with the exception of Dkt.
Nos. 173-5…
giuffre-maxwell
gov.uscourts.nysd.447706.1064.0
1 pg
…SUBSTITUTION OF
GHISLAINE MAXWELL, COUNSEL FOR
INTERVENOR ALAN M.
Defendant. DERSHOWITZ
------------------------------------------------------…
giuffre-maxwell
gov.uscourts.nysd.447706.117.0
2 pg
…action. I respectfully submit this declaration in
support of Defendant’s Opposition to Plaintiff’s Motion for Forensic Examination.
2. Attached as Exhibit A are true and correct copies of correspondence between
counsel for Ms. Maxwell and counsel for Ms…
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.447706.1199.22_1
10 pg
…Epstein and Virginia Roberts?
A. No.
Q. Were you ever present to view a massage between Jeffrey Epstein and Virginia
Roberts?
A. I don't recollect ever seeing Virginia and Jeffrey in a massage situation.
Q. Do you ever recollect…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…P. Specifically, Ms. Giuffre objects to the requests as
overly burdensome to the extent that they would require logging voluminous and ever-increasing
privileged communications between Ms. Giuffre and her counsel after the date litigation
commenced on September 21, 2015…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…TO INTERVENE
UNDER FEDERAL RULE OF CIVIL PROCEDURE 24(B) ..............................11
A. There Is Significant Overlap Between the Subject Matter
of the Original Action and This Motion ....................................................12
…
giuffre-maxwell
gov.uscourts.nysd.447706.1227.0
2 pg
…This suggestion
is entirely unworkable, as it would involve weeks of conferral between the Original Parties.
Further, Doe’s suggestion must be viewed against the legal backdrop of these proceedings – that
information filed on a docket enjoys a presumption of…
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.447706.1327.14
4 pg
…included within your Rule 26 disclosures. However, you never submitted a RFP seeking all
-
communications between our client and your witnesses. There are some RFPs which identify individual witnesses whose
communications with our client y…
giuffre-maxwell
gov.uscourts.nysd.447706.35.1
4 pg
…No. 12
All confidentiality agreements between you and Jeffrey Epstein or any entity to which he
is related or involved or such agreements which are or were in your possession or control related
to any other employee of Jeffrey Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1047.0
2 pg
…noting that Ms. Giuffre selected
filings “to speed up review of materials that [she] would like to
see unsealed first.”)) The present unsealing process is in many
ways a cooperative effort between the Court and the parties. It
will be…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…include all
documents of any nature that have been archived or placed in permanent or temporary storage
including electronic storage.
5. “Communication” means any transmission or exchange of information between
two or more persons, orally or in writing or otherwise…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.14
7 pg
…server?
6 A. I don't really know what, how, how to answer
7 your question because Citrix is for the whole
8 organization to exchange e-mail between employees.
9 Q. All right. You u…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.31
13 pg
…of sexual
assault.” (Br. at 5). (Emphasis original).
How Defendant purports to distinguish between the actual police reports as “relevant,” and
the information contained in the police reports as “irrelevant,” is unexplained. However, logic would
dictate that if the police…
giuffre-maxwell
gov.uscourts.nysd.447706.63.0
22 pg
…2008) ............................................................................. 6
iii
INTRODUCTION
This Court has inherent authority to control the order, means and method of discovery in
an action to promote fairness …
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