giuffre-maxwell
gov.uscourts.nysd.447706.303.0
13 pg
…33. She strenuously argues that she has
“disclosed” various treatment providers because their names are buried in records that she has
belatedly produced and which she obtained only after defense counsel had identified their
existence and absence through independent investigation…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.25_1
13 pg
…33. She strenuously argues that she has
“disclosed” various treatment providers because their names are buried in records that she has
belatedly produced and which she obtained only after defense counsel had identified their
existence and absence through independent investigation…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.1
8 pg
…and Maxwell and all their enablers began these
vicious attacks on their credibility. … No question about it. Maxwell knows
where a lot of the bodies are buried. If I was somebody who had participated in
their sex trafficking, um…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…DE 230 and Related Pleadings
Plaintiff’s response regarding DE 230 is largely the same as her response to DE 199
infra, with one significant exception: buried on page 19 of her Response to Ms. Maxwell’s
Objection to Unsealing…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.42
9 pg
…can make it. That's all there is. There is no other significance.
C. CUOMO: None of that could ever be buried. Living on in the hearts, and minds,
and actions of those who bear his name, who heeded his…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.18
50 pg
…2016, Subpoenas to Churcher and Weissfeld.
Yet, Defendant cited a number of cases wherein discovery was buried amid voluminous
productions so as to be hidden or to cause delayed or cumbersome discovery of them. They are
inapposite. Defendant didn’t…
giuffre-maxwell
gov.uscourts.nysd.447706.63.0
22 pg
…a chance to review either because
they were not produced or because they were produced so late in the day buried amidst
thousands of pages of meaningless discovery that her attorneys have not had the opportunity to
review and to…
giuffre-maxwell
gov.uscourts.nysd.447706.23.0
32 pg
…discussed infra. Ms. Giuffre has sufficiently pled libel, and many New York courts
have held that calling someone a liar constitutes libel. Buried in a string cite, and presented
without explanation or argument, Defendant cites Shenkman v. O'Malley, 2…
giuffre-maxwell
gov.uscourts.nysd.447706.755.0
75 pg
…Maxwell is
17 not doing Mr. Epstein's bidding and really could care less
18 about what Mr. Epstein says she should or should not do.
19 What is buried in these papers, your Honor, and is
20 very disingenuous…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.5
12 pg
…of Plaintiff’s hyperbole and indignation cannot change the simple fact that Plaintiff
willfully and intentionally set a bonfire and burned her journal that she admits contained
information relevant to test the allegations she made in the Crime Victims Right…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.42
5 pg
…I'm not too sure if they're the originals.
6 Q. The booklet that you gave pages from to Ms.
7 Churcher where is that booklet?
8 A. Burned.
9 Q. When did you burn it?
10 A. In…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.3
7 pg
…I don't.
16 Q Where are your notes?
17 A I burned them.
18 Q When did you burn them?
19 A In a bonfire when I lived at Titusville
20 because I was sick of going through this…
giuffre-maxwell
1320-30
27 pg
…2011 or 2012 in which you wrote
6 down your recollections about what had happened to
7 you, and you burned that in a bonfire in 2013.
8 Did I get that right?
9 A You got that right.
10…
giuffre-maxwell
gov.uscourts.nysd.447706.1118.0
21 pg
…in their pleadings and cannot satisfy it.
ARGUMENT
I. THE GOVERNMENT CANNOT INTERVENE OR MODIFY THE
PROTECTIVE ORDER FOR ACCESS TO NON-JUDICIAL DISCOVERY
MATERIALS
The Government buries the lead in its Motion. It first seeks four sets of documents…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.30
27 pg
…2011 or 2012 in which you wrote
6 down your recollections about what had happened to
7 you, and you burned that in a bonfire in 2013.
8 Did I get that right?
9 A You got that right.
10…
giuffre-maxwell
gov.uscourts.nysd.447706.555.0
21 pg
…to join the Crime Victims' Rights
I Act litigation ("CVRA Litigation") represented by her current counsel , Plaintiff willfully and
deliberately burned her long-ke tjoumal in a bonfire'in her backyard. According to Plaintiff,
I the JOUma] contained her tlfoughts…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…was in the process of trying to implead herself into the
CVRA case and under a preservation obligation, she and her husband had a bonfire and purposefully burned her
journal that she had kept for years containing relevant information. Specifically…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.19
22 pg
…I don't.
16 Q Where are your notes?
17 A I burned them.
18 Q When did you burn them?
19 A In a bonfire when I lived at Titusville
20 because I was sick of going through this…
giuffre-maxwell
1320-19
22 pg
…I don't.
16 Q Where are your notes?
17 A I burned them.
18 Q When did you burn them?
19 A In a bonfire when I lived at Titusville
20 because I was sick of going through this…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.13_1
23 pg
…I don't.
16 Q Where are your notes?
17 A I burned them.
18 Q When did you burn them?
19 A In a bonfire when I lived at Titusville
20 because I was sick of going through this…
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