giuffre-maxwell
gov.uscourts.nysd.447706.1059.0
3 pg
…There is no basis for such a
modification.
Mr. Dershowitz’s request is brought on plowed ground. In October 2017 third parties sued by
an alleged Epstein victim moved to modify the Protective Order to permit them to “use all…
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…has been a primary theater of battle in
this litigation over the past several months.1 Most notably, it
has been the subject of two separate requests seeking modification
brought by Alan Dershowitz, defendant in the related action Giuffre
v…
giuffre-maxwell
gov.uscourts.nysd.447706.967.0
7 pg
…Intervenors Jeffrey Epstein ("Epstein") and Lesley Groff
("Groff") requested unsealing of numerous documents concerning
the alleged relationship between Epstein and Jane Doe 43--a
witness who was deposed in this action and who brought an action
against Epstein and Groff …
giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…Epstein is not a defendant in this lawsuit and, most
importantly, plaintiff brought a defamation claim. Limine motions filed to prevent plaintiff from
introducing her speculative, salacious and always-uncorroborated allegations about sexual
encounters with others do not become anything…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…the Maxwell case is believed
to be particularly relevant to Dershowitz’s defense of the sexual assault claims which Giuffre has
brought against him on the theory that he was “on notice” that she was being sexually trafficked
by Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…action due to his death while in federal custody. Furthermore, the allegations brought in
the present complaint are demonstrably distinct from those brought by the USVI in its CICO
enforcement action. Therefore, the USVI satisfies this and all factors for…
giuffre-maxwell
gov.uscourts.nysd.447706.1069.0
25 pg
…literal language, we now
13 have Ms. Giuffre having brought claims that highly and
14 substantially overlap between the Maxwell case and the case now
15 brought against Professor Dershowitz.
16 But before I get to that, your Honor, I…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.27
11 pg
…. . as requested under
Rule 34” (emphasis supplied).
Local Civil Rule 37.1 provides that in any motion brought under Rule 37, including a
motion to compel, “the moving party shall specify and quote or set forth verbatim in the motion…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…criticize
Roberts’ lawyers — including Boies, saying that “he has some very hard questions to answer” — and
vowed to advocate for law reform that would prevent meritless claims from being brought against innocent
people. He told Big Law Business that he…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.17
13 pg
…Cernovich (Doc.920) and Mr. Dershowitz (Doc.915)
filed an appeal, which is pending.
In January 2017, while the case at bar was pending, the Giuffre lawyers brought a second
lawsuit, Doe 43 v. Epstein, No. 17-cv-616 (S…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.0
18 pg
…1024 (9th Cir. 1989).
A. Rule 21 Motion
Jane Doe 3 and Jane Doe 4’s first attempt to join in this proceeding was brought under
Rule 21. (DE 280). “If parties seek to add a party under Rule 21…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.7
11 pg
…5 make my objection on the record. Do not answer.
6 Objection, attorney/client privilege.
7 SPECIAL MASTER: So I'm going to grant
8 within the reservation it be brought back later.
9 BY MS. BORJA:
10 Q. Did…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…have moved pursuant to Federal Rule of Civil
Procedure 24 to intervene in this defamation action brought by
plaintiff Virginia Giuffre ("Giuffre" or the "Plaintiff")
against defendant Ghislaine Maxwell ("Maxwell" or the
"Defendant") and to unseal all of the documents…
giuffre-maxwell
gov.uscourts.nysd.447706.185.4
10 pg
…1024 (9th Cir. 1989).
A. Rule 21 Motion
Jane Doe 3 and Jane Doe 4’s first attempt to join in this proceeding was brought under
Rule 21. (DE 280). “If parties seek to add a party under Rule 21…
giuffre-maxwell
gov.uscourts.nysd.447706.946.0_1
14 pg
…as surrogate of the public. The motion to intervene and
unseal was brought in order to gain access to records that are germane to its ongoing coverage of
crimes committed by Jeffrey Epstein, the South Florida financier who pleaded guilty…
giuffre-maxwell
gov.uscourts.nysd.447706.149.0
9 pg
…Conduit, a former United States Congressman brought a
defamation action against a media commentator based on statements made regarding the
disappearance and death of a Washington intern. The defendant filed a motion to compel the
plaintiff to provide deposition testimony…
giuffre-maxwell
gov.uscourts.nysd.447706.406.0
31 pg
…2016.
III. THE PROTECTIVE ORDER IN THIS CASE
This is a case concerning sex abuse of minors, brought by a woman who was herself a
minor victim of sex abuse. Accordingly, this Court has recognized from the outset the paramount…
giuffre-maxwell
gov.uscourts.nysd.447706.23.0
32 pg
…Ms. Giuffre sought to
join a long-running Crime Victims’ Rights Act (“CVRA”) lawsuit, which was brought by other
young girls who were also abused, and sought to challenge Jeffrey Epstein’s non-prosecution
agreement which also pardoned co-conspirators…
giuffre-maxwell
gov.uscourts.nysd.447706.1226.0
4 pg
…objection is not a
basis for delaying the next phase under the Protocol.
2. The legal briefing before the Court should be brought to a conclusion. The
Protocol established a deadline for the original parties’ response to any non-party
…
giuffre-maxwell
gov.uscourts.nysd.447706.542.5
11 pg
…1024 ( 9th Cir. 1989).
A. Rule 21 Motion
Jane Doe 3 and Jane Doe 4' s first attempt to join in this proceeding was brought under
Rule 21. ( DE 280). " If parties seek to add a party under Rule 21…
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