giuffre-maxwell
gov.uscourts.nysd.447706.1067.0
10 pg
…attaches to all judicial documents.
Maxwell’s repeated assertion that these documents are entitled to “a minimal presumption of
access” is directly contradicted by the Second Circuit’s conclusion that “the presumption of access
to “materials submitted in connection with…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…his guilty plea and associated non-prosecution agreement. Dershowitz
uniquely would have been aware of the compelling evidence against Epstein — and no doubt
would have taken a keen interest in the evidence that would have connected him with Epstein's…
giuffre-maxwell
gov.uscourts.nysd.447706.185.8
24 pg
…any
purported “privacy interest” in proceeding anonymously.
2
Case 1:15-cv-07433-LAP Document 185-8 Filed 06/01/16 Page 4 of 24
slave” who was sexually trafficked by Jeffrey Epstein (“Epstein”) to his purported associates.
Second…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…attending to an Alzheimer's Association event in New York in 2010
2/6
Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 8 of 161
It raises serious questions as to why Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.15.0
29 pg
…Enters, Inc., 209 F.3d 163 (2d Cir. 2000) .............................. 17
Club Valencia Homeowners Ass’n, Inc. v. Valencia Associates, 712 P.2d 1024 (Colo.
App. 1985) ..................................................................................................................... 13
Cohen v. Stevanovich, 772 F.Supp.2d 416,…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…was telling the truth. To
prove the truth of her sexual abuse, Ms. Giuffre seeks discovery of documents evidencing her
sexual abuse and sexual trafficking by Maxwell and her associates, including convicted sex
offender Jeffrey Epstein. Therefore, documents evidencing Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…clear, the only massage I recall receiving at the Epstein home was
conducted by a professional masseuse—a woman in her in her 30s or 40s. This occurred well
outside the timeframe when Ms. Giuffre was associated with Mr. Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…proof” that Professor
Dershowitz had ever done anything wrong; and that Ms. Giuffre concocted her malicious
allegations against Professor Dershowitz, and used his name in her statements and book
proposal, not because he abused her—he didn’t—but because…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…people that you knew to have been
associated with the house in those message pads?
THE WITNESS: Yes.
Q. And so what was the evidentiary value to you of the message pads collected
from Jeffrey Epstein's home in the…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…people that you knew to have been
associated with the house in those message pads?
THE WITNESS: Yes.
Q. And so what was the evidentiary value to you of the message pads collected
from Jeffrey Epstein's home in the…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…Tr. at 163:6-8 (July 22, 2016) (McCawley Decl. at Exhibit 3).
The Dubins are closely connected to this case. Indeed, Rinaldo Rizzo, the Dubins’ butler,
was in tears as he recounted Defendant bringing a fifteen-year-old girl…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
…clear, the only massage I recall receiving at the Epstein home was
conducted by a professional masseuse—a woman in her in her 30s or 40s. This occurred well
outside the timeframe when Ms. Giuffre was associated with Mr. Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…people that you knew to have been
associated with the house in those message pads?
THE WITNESS: Yes.
Q. And so what was the evidentiary value to you of the message pads collected
from Jeffrey Epstein's home in the…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…2015, Maxwell again issued a statement,
responding to the allegations made in connection with Giuffre's
Joinder Motion. Maxwell stated that Giuffre's allegations
"against Ghislaine Maxwell are untrue" and that Giuffre's
"claims are obvious lies" (the "January 3…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.1
17 pg
…people that you knew to have been
associated with the house in those message pads?
THE WITNESS: Yes.
Q. And so what was the evidentiary value to you of the message pads collected
from Jeffrey Epstein's home in the…
giuffre-maxwell
gov.uscourts.nysd.447706.435.0
27 pg
…clear, the only massage I recall receiving at the Epstein home was
conducted by a professional masseuse—a woman in her in her 30s or 40s. This occurred well
outside the timeframe when Ms. Giuffre was associated with Mr. Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.6
32 pg
…proof” that Professor
Dershowitz had ever done anything wrong; and that Ms. Giuffre concocted her malicious
allegations against Professor Dershowitz, and used his name in her statements and book
proposal, not because he abused her—he didn’t—but because…
giuffre-maxwell
gov.uscourts.nysd.447706.53.0
15 pg
…2015.
2
or disprove the claim in this case.6 Defendant cannot hold the position that documents relevant
to the claim in this case arise solely from a self-serving fraction of the requested date range if
collected from her…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.18
50 pg
…2
1. Ms. Giuffre’s Counsel’s Communications With the Media Are
Outside the Scope of Rule 26 and Any Attempt at Collection Would
be Unduly Burdensome ..............................................................................2
…
giuffre-maxwell
gov.uscourts.nysd.447706.1122.0_2
13 pg
…There are at least two
circumstances connected with this litigation that give rise to the USVI’s compelling need.
The first is Jeffrey Epstein’s passing after he was deposed as a fact witness in this action,
but before the…
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