giuffre-maxwell
gov.uscourts.nysd.447706.1210.0_1
3 pg
…2019). In recognizing this reliance interest,
the Court of Appeals redacted Ms. Maxwell’s testimony related to
her consensual sexual activity with adults, but unsealed
testimony related to purportedly non-sexual massages, finding
that the presumption of public access was…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…this case” (Brief at 2);
• Ms. Maxwell objected to the second deposition, based in part on her privacy
concerns about testifying to her adult consensual activity (id.);
• Judge Sweet overruled Ms. Maxwell’s objections to the deposition, ruling that her
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.35
10 pg
…were the “same age as me.” Plaintiff well knows that it is irrelevant to
this lawsuit whether Ms. Maxwell engaged in consensual, adult sexual activities with women.
There is no allegedly defamatory statement that has anything to do with Ms…
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.447706.1191.0_1
3 pg
…this Court recognized in its January 19 order, the limited presumption of
access applicable to these discovery filings was overcome by Ms. Maxwell’s interest in
keeping private the details of her own consensual, sexual activity. TR 1/19/2021…
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.447706.1196.0
32 pg
…not up to this
16 Doe yet.
17 The last sentence in paragraph 1 under argument may be
18 unsealed. The next sentence, the material relating to adult
19 consensual behavior, should be redacted. And by way of
20 notation…
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.447706.1201.10_1
27 pg
…privilege against self-
incrimination and was questioned extensively about, among other things: her relationship with
Jeffrey Epstein, her knowledge of “sexual trafficking,” sex with minors, non-consensual sex, sex
involving the Plaintiff and others, sex involving Plaintiff and Mr. Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…of course, has relevant information
in this case. But when Defendant was deposed, she refused to answer numerous questions about
alleged adult consensual sex. Those refusals are currently before the Court in a pending motion
to compel. DE 155. And…
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.447706.1320.10
28 pg
…of course, has relevant information
in this case. But when Defendant was deposed, she refused to answer numerous questions about
alleged adult consensual sex. Those refusals are currently before the Court in a pending motion
to compel. DE 155. And…
giuffre-maxwell
gov.uscourts.nysd.447706.1067.0
10 pg
…victims. The Miami
Herald’s coverage of Mr. Epstein’s and his associates’ alleged crimes has nothing to do with
consensual sexual preferences and everything to do with the abuse of young girls, whether that
crime was justly prosecuted or…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.26
27 pg
…privilege against self-
incrimination and was questioned extensively about, among other things: her relationship with
Jeffrey Epstein, her knowledge of “sexual trafficking,” sex with minors, non-consensual sex, sex
involving the Plaintiff and others, sex involving Plaintiff and Mr. Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…of course, has relevant information
in this case. But when Defendant was deposed, she refused to answer numerous questions about
alleged adult consensual sex. Those refusals are currently before the Court in a pending motion
to compel. DE 155. And…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
… 539 U.S. 558, 573 (2003) (holding that
persons in a homosexual relationship may seek autonomy in their
consensual sexual conduct in the home just as heterosexual
persons do), "and with subterfuge and concealment, " see U.S.
Dep't of…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.3
28 pg
…of course, has relevant information
in this case. But when Defendant was deposed, she refused to answer numerous questions about
alleged adult consensual sex. Those refusals are currently before the Court in a pending motion
to compel. DE 155. And…
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
1320-10
28 pg
…of course, has relevant information
in this case. But when Defendant was deposed, she refused to answer numerous questions about
alleged adult consensual sex. Those refusals are currently before the Court in a pending motion
to compel. DE 155. And…
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…
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