giuffre-maxwell
gov.uscourts.nysd.447706.1137.2_2
4 pg
…t have
15 any problem with you asking that
16 question. To the extent these questions
17 involve consensual acts between adults,
18 frankly, they're none of your business
19 and I will instruct the wi tness not to…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.1_1_1_1
10 pg
…questions.
Yet during her deposition, Defendant refused to answer any questions that she construed
as having something to do with ·•consensual adult sex." Defense counsel supported that position
that "frankly, [that's] none of your business and I instruct…
giuffre-maxwell
gov.uscourts.nysd.447706.143.0
10 pg
…10
Yet during her deposition, Defendant refused to answer any questions that she construed
as having something to do with “consensual adult sex.” Defense counsel supported that position
that “frankly, [that’s] none of your business and I instruct the…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.5_2
4 pg
…masseuse pinch his
20 nipples while he was having a massage?
21 A. I 1 m not talking about anything with
22 consensual adult situation.
23 Q. What about with underage
24 A. I am not aware of anything.
25…
giuffre-maxwell
1320-2
10 pg
…10
Yet during her deposition, Defendant refused to answer any questions that she construed
as having something to do with ''consensual adult sex." Defem,e counsel supported that position
that "frankly, [that's] none of your business and I instruct…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.8_3
9 pg
…Maxwell, pursuant to Rule 30(d)(3) of the Federal Rules of Civil Procedure, moves to
prohibit Plaintiff from asking her questions about any adult, consensual sex. In support of her
requests, Ms. Maxwell states:
Plaintiff initiated this action purportedly…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.2
10 pg
…10
Yet during her deposition, Defendant refused to answer any questions that she construed
as having something to do with ''consensual adult sex." Defem,e counsel supported that position
that "frankly, [that's] none of your business and I instruct…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.18
11 pg
…that Ms. Maxwell did not invoke the
Fifth Amendment and she testified fully and answered every question posed to her with the only
exception the irrelevant and harassing questions Plaintiff posed to her concerning her adult,
consensual sexual activities. In…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…the perception of Ms. Maxwell, including on topics such as Ms. Maxwell’s adult consensual
sexual activities. Last week, Plaintiff’s counsel filed in a public pleading apparently confidential
information regarding the settlement terms of Mr. Edwards and Cassell’s…
giuffre-maxwell
gov.uscourts.nysd.447706.1211.0_1
5 pg
…at page 112,
line 17 though page 113, line 12 on the basis that (1) this
portion of testimony falls within the category of adult,
consensual activity that warrants sealing and, to the extent the
testimony was not sexual in…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.20
11 pg
…that Ms. Maxwell did not invoke the
Fifth Amendment and she testified fully and answered every question posed to her with the only
exception the irrelevant and harassing questions Plaintiff posed to her concerning her adult,
consensual sexual activities. In…
giuffre-maxwell
1320-20
11 pg
…that Ms. Maxwell did not invoke the
Fifth Amendment and she testified fully and answered every question posed to her with the only
exception the irrelevant and harassing questions Plaintiff posed to her concerning her adult,
consensual sexual activities. In…
giuffre-maxwell
gov.uscourts.nysd.447706.189.0
11 pg
…that Ms. Maxwell did not invoke the
Fifth Amendment and she testified fully and answered every question posed to her with the only
exception the irrelevant and harassing questions Plaintiff posed to her concerning her adult,
consensual sexual activities. In…
giuffre-maxwell
gov.uscourts.nysd.447706.66.0_1
35 pg
…order in this case. You are good
2 lawyers and you have been around this track more times than I
3 have and so you can prepare consensually a better protective
4 order than I can, and I urge you…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.39
36 pg
…order in this case. You are good
2 lawyers and you have been around this track more times than I
3 have and so you can prepare consensually a better protective
4 order than I can, and I urge you…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.50
15 pg
…This explains the nearly
uniform consensus among the district courts bound by its decisions in applying the presumption
3
Case 1:15-cv-07433-LAP Document 1218-50 Filed 07/15/21 Page 8 of 15
of access to…
giuffre-maxwell
gov.uscourts.nysd.447706.436.0
15 pg
…This explains the nearly
uniform consensus among the district courts bound by its decisions in applying the presumption
3
Case 1:15-cv-07433-RWS Document 436 Filed 09/15/16 Page 8 of 15
of access to discovery…
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