giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…Mr. Dershowitz is the defendant in a lawsuit identical to this one. Since at least 2011
plaintiff has been selling her story to the media, telling ever more salacious stories about her
alleged sexual encounters with ever more prominent men…
giuffre-maxwell
gov.uscourts.nysd.447706.949.0
31 pg
…22 the file. But I think the circumstances have changed now and
23 the situation has changed now such that the Court should be in
24 a position where it should look favorably on our motion.
25 First, your Honor…
giuffre-maxwell
gov.uscourts.nysd.447706.49.0
12 pg
…3
A. The Proposed Opening Paragraph and the Purposes and Limitations
Paragraph are Based on False Premises ................................................................ 3
B. The Proposed Changes to Paragraph 3 are Unnecessary ........................................ 4
C. …
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…party to, witness to events that I have never seen,
living off trust funds that I have never ever had, party to stories that have changed
materially both in time place and event, depending on what paper you read, and…
giuffre-maxwell
1320-28
32 pg
…party to, witness to events that I have never seen,
living off trust funds that I have never ever had, party to stories that have changed
materially both in time place and event, depending on what paper you read, and…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…O.J. Simpson: American Crime Story. We have a Friday
night news dump on our hands.
Case 1:15-cv-07433-LAP Document 363-11 Filed 08/11/16 Page 3 of 40
The defamation case filed against Dershowitz…
giuffre-maxwell
gov.uscourts.nysd.447706.1215.0
13 pg
…Denver, CO 80203
303.831.7364
Case 1:15-cv-07433-LAP Document 1215 Filed 02/19/21 Page 2 of 13
INTRODUCTION1
Plaintiff cannot get her story straight.
In her Response in Opposit…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.0
35 pg
…jury, unsealing the deposition material also risks compromising the integrity of witness
testimony because it provides an opportunity for a witness to change his or her story to conform
to the allegations made in the unsealed (and publicized) material.” Id…
giuffre-maxwell
gov.uscourts.nysd.447706.23.0
32 pg
…against Ghislaine Maxwell are untrue. The original allegations are not new and have been
fully responded to and shown to be untrue. Each time the story is retold it changes, with new salacious details about
public figures. (The woman’s…
giuffre-maxwell
gov.uscourts.nysd.447706.872.0
76 pg
…one party must prevail as a matter of law." Id. at 251-52. A
court is not charged with weighing the evidence and determining
its truth, but with determining whether there is a genuine issue
I for trial. Westinghouse Elec…
giuffre-maxwell
gov.uscourts.nysd.447706.25.0
13 pg
…the Statement referencing “obvious lies” immediately follows the
sentence: “Each time the story is retold it changes, with new salacious details about public
figures.” Even Judge Marra noted in his April 7 Order that Plaintiff’s latest story involves
3
…
giuffre-maxwell
gov.uscourts.nysd.447706.1105.0
8 pg
…interests.
I. Mr. Dershowitz’s Proposed Disclosure of Confidential Maxwell Materials
Nothing material has changed since Mr. Dershowitz’s last application to receive materials
protected by the Protective Order or otherwise filed under seal in the instant matter. The Court…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.36
4 pg
…Mr.
8 Epstein?
9 A. I started working for him at some
10 point in 1992 and the nature of my work
11 relationship with him changed over time so
12 from around 2002, 2003, the work lessened
13 considerably…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…argument
on appeal that was raised for the first time below in a motion for reconsideration.”). Moreover,
the known facts have changed. The way in which the government obtained both the first and
second Maxwell depositions is different from what…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…denied.
C. Jean Luc Brunel
With regard to Jean Luc Brunel, Plaintiff simply asserts that he was “subpoenaed,” and
“set for mid-June deposition[],” but “through counsel” has “requested we change the dates of
[his] deposition.” Mot. at 4. That…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.3
21 pg
…mental impressions, and work product the keystone
5
Case 1:15-cv-07433-LAP Document 1332-3 Filed 01/08/24 Page 10 of 21
of her argument, things changed. Ms. Giuffre is entitled to present those changed circumstances…
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…dkt. no. 1113]
at 5.) The USVI points to no changed circumstance that would
require the Court to perform an about-face on that conclusion.
Similarly, the USVI seeks the requested materials as a matter
of “procedural efficiency.” (USVI Br…
giuffre-maxwell
gov.uscourts.nysd.447706.79.1
12 pg
…in
14 fairness to plaintiff's counsel, I should alert the Court to
15 that series of events and I am not sure how that changes the
16 Court's analysis. I do agree and it was part of our…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.10
64 pg
…what the media did in this
-
21 case, you can't hold Ms. Maxwell liable for that republication.
22
23
-- You change the meaning. How do you change the meaning?
changed the meaning because …
giuffre-maxwell
gov.uscourts.nysd.447706.82.0_2
11 pg
…in
14 fairness to plaintiff's counsel, I should alert the Court to
15 that series of events and I am not sure how that changes the
16 Court's analysis. I do agree and it was part of our…
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