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.447706.1328.28
24 pg
…a past or present officer, director, agent or servant, including
any attorney (associate or partner) or paralegal.
7. “Including” means including without limitations.
8. “Jeffrey Epstein” includes Jeffrey Epstein and any entities owned or controlled by
Jeffrey Epstein, any employee…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…a past or present officer, director, agent or servant, including
any attorney (associate or partner) or paralegal.
6. "Including'' means including ·without limitations.
7. "Jeffrey Epstein" includes Jeffrey Epstein and any entities owned or controlled by
Jeffrey Epstein, any employee…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.32
27 pg
…a past or present officer, director, agent or servant, including
any attorney (associate or partner) or paralegal.
5. "Including" means including without limitations.
6. "Jeffrey Epstein" includes Jeffrey Epstein and any entities owned or controlled by
Jeffrey Epstein, any employee…
giuffre-maxwell
gov.uscourts.nysd.447706.223.1
14 pg
…a past or present officer, director, agent or servant, including
any attorney (associate or palinel') or paralegal.
7. "Including" means including without limitation.
g. "Jeffrey Epstein" includes Jeffrey Epstein and any entities owned or coniTolled by
Jeffrey Epstein, any employee…
giuffre-maxwell
1320-32
27 pg
…a past or present officer, director, agent or servant, including
any attorney (associate or partner) or paralegal.
5. "Including" means including without limitations.
6. "Jeffrey Epstein" includes Jeffrey Epstein and any entities owned or controlled by
Jeffrey Epstein, any employee…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.29
24 pg
…a past or present officer, director, agent or servant, including
any attorney (associate or partner) or paralegal.
7. “Including” means including without limitations.
8. “Jeffrey Epstein” includes Jeffrey Epstein and any entities owned or controlled by
Jeffrey Epstein, any employee…
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.447706.1351.0
32 pg
…Giuffre charged defendant
Ghislaine Maxwell, an Epstein associate, with defaming her by publicly
calling her statements implicating Maxwell in Epstein’s trafficking “obvious
6
Case:
Case:24-182,
24-182,01/08/2026,
07/2…
giuffre-maxwell
gov.uscourts.nysd.447706.1349.0
31 pg
…a victim of
sexual trafficking by financier Jeffrey Epstein. Giuffre charged defendant
Ghislaine Maxwell, an Epstein associate, with defaming her by publicly
calling her statements implicating Maxwell in Epstein’s trafficking “obvious
6
Case: 24-182, 07/23/2025…
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.447706.1062.0
7 pg
…of the Reliance
Finally, courts examine the ways in which those from whom discovery is sought – both
parties and non-parties – conducted themselves in reliance on a protective order. For example,
courts consider whether discovery was provided that otherwise could…
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.447706.1327.19
21 pg
…Defendant’s London-based press agent, who
shares Defendant’s attorney, Philip Barden, and who was connected with Defendant’s statements
about Ms. Giuffre in both 2011 and 2015. Defendant admitted that she used Mr. Gow in 2011 in
relation…
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.447706.849.0
94 pg
…like to start with
19 Kliman, if I could.
20 Dr. Kliman is a summary witness who has no firsthand
21 knowledge about the facts associated with this case. He's been
22 proffered as an expert in psychiatry. And…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.13
15 pg
…Central Park Five” case in
connection with the civil lawsuit by the individuals who were wrongfully convicted in that case.
The City argued that the privilege did not apply because the filmmakers first conducted
interviews with one of the plaintiffs…
giuffre-maxwell
gov.uscourts.nysd.447706.847.0
94 pg
…like to start with
19 Kliman, if I could.
20 Dr. Kliman is a summary witness who has no firsthand
21 knowledge about the facts associated with this case. He's been
22 proffered as an expert in psychiatry. And…
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