giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…ofPage
01/21/2015 41 2 of 40
sworn affidavit (attached as Exhibit 1) that all her allegations are true – an affidavit consistent
with compelling corroborating evidence.
BACKGROUND AND COURSE OF PROCEEDINGS
Because this case …
giuffre-maxwell
gov.uscourts.nysd.447706.40.0
8 pg
…by the non-party designated
“CONFIDENTIAL” or ““HIGHLY CONFIDENTIAL—ATTORNEYS’ EYES
ONLY” shall be subject to the restrictions contained in this Order and shall only
be disclosed or used in a manner consistent with this Order.”
5
Paragraph 14…
giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…There, the court recognized that a non-party’s privacy interest
should be protected “if this can be done in a manner consistent with the public’s reasonable interest
in access to evidence relating to Plaintiffs’ equal protection claim.” Id…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…Her consistent failure to adhere to the
3
Case 1:15-cv-07433-LAP Document 1068 Filed 06/24/20 Page 8 of 24
Second Circuit’s directive to provide specific reasons as to why specific documents should remain…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…underage girls.” Id. ¶ 21(p). Mr. Cassell describes this as “a
pattern of deception” that was “consistent with a pattern of other persons involved in Epstein’s
international sex trafficking organization.” Id. ¶ 21(p)-(q). Again, these assertions are false…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…19.
26
“This matter being subject to a Protective Order, the parties are directed to meet and confer regarding redactions
to this Opinion consistent with that Order. The parties are further directed to jointly file a proposed redacted version
of…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.17
6 pg
…will add to our log. We also located a number of
privileged communications between our client and myself following the onset of litigation in this case which
will not be logged consistent with both parties' agreed to practice. As predicted…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…Additional sealed and related items
include DE 190-1 (portions of Plaintiff’s deposition) and redactions of the motion papers
consistent with the sealed materials.
15
Case 1:15-cv-07433-LAP Document 1073 Filed 07/01/20 Page…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…122:5;
40:19-47:14
interactions with Mr. Epstein 126:22-129:12
1
Consistent with Ms. Maxwell’s testimony,
.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1237.0
20 pg
…extensive prior briefing on objections just like these, the Court’s unsealing process
has been quite consistent: with the exception of a narrow set of circumstances which are generally
not present here, documents have been unsealed notwithstanding generalized concerns about…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.27
8 pg
…MR. EDWARDS:
25 Q. That's something that ran consistent with
Case 1:15-cv-07433-LAP Document 1201-27 Filed 01/27/21 Page 7 of 8
Page 83
1 JOSEPH RECAREY - CONFIDENTIAL
2 BY MR. EDWARDS:
3 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1284.0
17 pg
…144-6.
12 MS. McCAWLEY: OK. Thank you, your Honor.
13 THE COURT: That was the first document we did.
14 Does that appear consistent to you?
15 MS. McCAWLEY: Let me see. The first document we
16 did --
17…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.8
12 pg
…delivery to a
named person is to ‘ensure receipt, so that notice will be provided to the recipient, and
enforcement of the subpoena will be consistent with the requirements of due process.’”
Aristocrat Leisure Ltd. v. Deutsche Bank Trust Co…
giuffre-maxwell
gov.uscourts.nysd.447706.1283.0
17 pg
…144-6.
12 MS. McCAWLEY: OK. Thank you, your Honor.
13 THE COURT: That was the first document we did.
14 Does that appear consistent to you?
15 MS. McCAWLEY: Let me see. The first document we
16 did --
17…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…delay the
investigation;
• Dershowitz's pattern of avoiding depositions (and helping Epstein avoid
questioning) was consistent with a pattern of other persons who were involved in
Epstein's international sex trafficking organization evading efforts to obtain
information from them;
• Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.26
27 pg
…10;
Farmer 62:21-25 103:19-113:22
Her knowledge of Nadia Marcinkova and
interactions with Mr. Epstein
-
40:19-47:14
…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
…underage girls.” Id. ¶ 21(p). Mr. Cassell describes this as “a
pattern of deception” that was “consistent with a pattern of other persons involved in Epstein’s
international sex trafficking organization.” Id. ¶ 21(p)-(q). Again, these assertions are false…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.50
15 pg
…support of any
part of the court’s adjudicatory function.” Rosado, 970 A.2d at 678 (emphasis added)
(describing the Second Circuit’s approach as consistent with Mokhiber). This explains the nearly
uniform consensus among the district courts bound by…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…The parties,
in accordance with the agreed upon procedures, were directed to
jointly file a proposed redacted version of the Summary Judgment
Opinion consistent with the Protective Order. The agreed upon
redacted opinion was filed with the Court and made…
giuffre-maxwell
1320-8
12 pg
…delivery to a
named person is to ‘ensure receipt, so that notice will be provided to the recipient, and
enforcement of the subpoena will be consistent with the requirements of due process.’”
Aristocrat Leisure Ltd. v. Deutsche Bank Trust Co…
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