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.447706.364.0
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.447706.1219.31
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.447706.1331.25
4 pg
…of 4
ROSS NEIL· SUTHERLAND GOW - 11/18/2016 ·
·1· · · · · · · · ·IN THE HIGH COURT OF JUSTICE
· · · · · · · · · · · QUEEN'S BENCH DIVISION
·2
·3· · · · · · · · · · ·Claim No. CR 2016-624
·4· ·BETWEEN:
·5· · · · · · · · · · · VIRGINIA L. GIUFFRE
· · · · · · · · · · · · · · · · · · · · · …
giuffre-maxwell
gov.uscourts.nysd.447706.919.0
2 pg
…DISMISSAL
Plaintiff, VIRGINIA GIUFFRE, and Defendant, GHISLAINE MAXWELL, by and
through their undersigned counsel, hereby stipulate and agree that pursuant to the Settlement
Agreement entered into between the parties and Fed. R. Civ. P. 4l(a)(l)(A)(ii), this…
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.447706.263.0
14 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.447706.916.0
2 pg
…DISMISSAL
Plaintiff, VIRGINIA GIUFFRE, and Defendant, GHISLAINE MAXWELL, by and
through their undersigned counsel, hereby stipulate and agree that pursuant to the Settlement
Agreement entered into between the parties and Fed. R. Civ. P. 41(a)(1)(A)(ii), this…
giuffre-maxwell
gov.uscourts.nysd.447706.223.5
3 pg
… [email protected]
Subject: Fw: SERVICE· Epstein Deposition
Ms Schultz, just wanting to be sure there are no email issues between Sigrid and
myself. Below is an email sent to Sigrid shortly after noon today.
Martin Weinberg
From: Martin Weinberg…
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.447706.55.15
2 pg
…Ghislaine is putting the word out to her wealthy friends
that she is ready to sell,” and wants more than $20 million.
Ghislaine Maxwell on the Upper East Side Perhaps she hopes to put some distance between herself and Epstein…
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.447706.961.0
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.447706.57.2
30 pg
…WC2A 2LL
Date: 1 March 2004
Before :
THE HONOURABLE MR JUSTICE MANN
---------------------
Between :
…
giuffre-maxwell
gov.uscourts.nysd.447706.57.1
26 pg
…to privilege to succeed—
Whether form of wording of report conclusive as to purpose
for which prepared
The plaintiff's husband was employed by the defendant
railways board. In a collision between locomotives, he
received injuries from which he died…
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