giuffre-maxwell
gov.uscourts.nysd.447706.139.0
7 pg
…the Court’s Order [DE 134] dated May 2, 2016.1
ARGUMENT
Statements made by witnesses to law enforcement are protected by the public interest
privilege, which “exists to encourage witnesses to come forward and provide information in
criminal investigations . . …
giuffre-maxwell
gov.uscourts.nysd.447706.1219.24
6 pg
…of Florida.
Case 1:15-cv-07433-LAP Document 1219-24 Filed 07/15/21 Page 3 of 6
Page 28
1 JOHN ALESSI
2 Q. And where did the massage therapists --
3 where did they come from?
4 A…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.17
6 pg
…names
somehow yield thousands of documents, please let me know, and I’m certain we can come to an agreement to
adjust the term so as to not yield an unmanageable result. As it is, I would expect these discrete…
giuffre-maxwell
gov.uscourts.nysd.447706.751.12
3 pg
…with their little bathing suits on, like they had just come from the beach.
'She’d have like $4,000. And then I’d take them all to the mall and they’d get their nails done.'
He also said…
giuffre-maxwell
gov.uscourts.nysd.447706.1021.0
18 pg
…this review.
15 THE COURT: Bless you, my daughter.
16 MS. McCAWLEY: A few ideas that we have come up
17 with -- we have submitted the letter to you, obviously, which
18 poses an approach dealing with the non-parties…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.37
11 pg
…happened when she approached you?
12 A. She asked me if I could tell her how to
13 find someone that would come and work at her house.
14 She wanted to know if there was, like, a bulletin
15 …
giuffre-maxwell
gov.uscourts.nysd.447706.1330.19
15 pg
…of conversations
since 2002, 2003 that a conversation in which
22
23
24
-
possible.
Q.
name would have come up is entirely
I provided you with and I'm sorry,
25 I don't know all the numbers, but the
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.6
9 pg
…sir.
6 answer, and you have to wait until I finish my question, 6 Q And when the guests would come over, would you
7 because if we talk over one another, then the court 7 stay in the main…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.13
9 pg
…sir.
6 answer, and you have to wait until I finish my question, 6 Q And when the guests would come over, would you
7 because if we talk over one another, then the court 7 stay in the main…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.24
6 pg
…system at
13 the house, that it was MindSpring, MindSpring I
14 think it's called, that it was like a message system
15 that would come from the office.
16 Q. What is MindSpring?
17 A. It was a…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.12
35 pg
…happened when she approached you?
12 A. She asked me if I could tell her how to
13 find someone that would come and work at her house.
14 She wanted to know if there was, like, a bulletin
15 …
giuffre-maxwell
gov.uscourts.nysd.447706.1327.29
35 pg
… I did.
25 Q. And how did that come about?
MAGNA9 LEGAL SERVICES
Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 4 of 35
Page 25
1 And I can't recall if they…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.27
5 pg
…probably wouldn't remember her at
13 all, except she did come from time to time
14 but I don't recollect her coming as often as
15 she portrayed herself.
16 Q. How many times a day on an…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.7
11 pg
… It's a moment to take a break and I'll
4 discuss with these folks and we'll come back.
5 THE VIDEOGRAPHER: Going off video record
6 2:25 p.m.
7 (A recess was taken.)
8 THE…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.16
10 pg
…credibility and vouching opinions. This is the subject matter of Dr. Esplin’s rebuttal report
which explains that there is no reliable or scientific methodology by which an expert could
reliably come to such opinions. Of course, if the improper…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.18
6 pg
…system at
13 the house, that it was MindSpring, MindSpring I
14 think it's called, that it was like a message system
15 that would come from the office.
16 Q. What is MindSpring?
17 A. It was a…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.36
4 pg
…5 to be talking about general background,
6 I don't need to designate that as
7 confidential. So if you want to have
8 them come back in, that's fine.
9 I assumed by your first question
10 …
giuffre-maxwell
gov.uscourts.nysd.447706.961.0
9 pg
…in questions are being securely held, so no harm will come from allowing the appellate process
to run its ordinary course.
This Court should deny the motion.
2
Defendant’s counsel have neither advised Ms. Giuffre’s counsel that Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.279.0
8 pg
…Order was July 11, 2016. The deadline has come and gone without any
production whatsoever by Defendant. Defendant completely disregarded this deadline and has
not produced a single document in violation of this Court’s order. Defendant has not provided…
giuffre-maxwell
gov.uscourts.nysd.447706.931.0
15 pg
… This issue has been before the Court two times
12 previously where a non-party has come before the Court seeking
13 to modify the protective order with respect to designations.
14 I also want to point out we do…
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