giuffre-maxwell
gov.uscourts.nysd.447706.755.0
75 pg
…but you can see the defendant, Ms. Maxwell,
11 and Mr. Epstein talking about fabricating evidence by producing
12 a non-existent witness who will cover up for Ms. Maxwell.
13 MR. PAGLIUCA: Your Honor, I object to this.
14…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…substantial payout, directly from the Clinton Foundation to keep her quiet.
She is 1000% certain that the FBI did a cover up and she has the individual names of Hilary’s
Special Agent Officers involved in intimidating her. She was…
giuffre-maxwell
gov.uscourts.nysd.447706.43.0
15 pg
…sex offender Jeffrey Epstein and Defendant were engaging in sexual trafficking conduct;
the later part of that period includes the investigations by law enforcement and the co-
conspirator’s efforts to coordinate and cover up the abuse that occurred. Therefore…
giuffre-maxwell
gov.uscourts.nysd.447706.849.0
94 pg
…and denying us the ability, because of the redactions, to
5 cross-examine her about what she actually said because the
6 redactions cover up the content for the most part.
7 Your Honor, prior consistent statements, I think our
…
giuffre-maxwell
gov.uscourts.nysd.447706.847.0
94 pg
…and denying us the ability, because of the redactions, to
5 cross-examine her about what she actually said because the
6 redactions cover up the content for the most part.
7 Your Honor, prior consistent statements, I think our
…
giuffre-maxwell
gov.uscourts.nysd.447706.53.0
15 pg
…receipt of payments from Epstein, and documents showing her attempts to
cover up her wrongful sexual abuse of minors are relevant.
There are already materials implicating Defendant’s post-2008 involvement with Epstein
and the related cover-up. For example…
giuffre-maxwell
gov.uscourts.nysd.447706.57.2
30 pg
…or otherwise restrain witnesses from giving evidence, because the defendants
are using privilege to cover up wrong-doing (a sort of "clean hands" point), the claimants
Case 1:15-cv-07433-RWS Document 57-2 Filed 03/14/16…
giuffre-maxwell
gov.uscourts.nysd.447706.1188.0
3 pg
…names of Does 55, 56,
and 93 only appear in motions that Doe 151’s name also appears in, so the parties and the Court
would be able to cover four Non-Parties at once. Further, this proposal would not…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…15 Here's my concern, your Honor, I guess: If there's a
16 witness that shows up in court, I think it's prejudicial to the
17 defendant if we're using initials or things like that, because
18 …
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…the Court’s suggestion due to scheduling conflicts until January of next year, and asserted
1
The Non-Party Objectors’ documents cover approximately 200 to 250 docket entries, a list of
which the Parties can exchange in advance of briefing…
giuffre-maxwell
gov.uscourts.nysd.447706.57.3
39 pg
…working for Total, must be reported. It is also stated that the guide covers
E investigation and that the investigation’s purpose is to examine the events leading up
to the incident, during the incident and the final outcome. This…
giuffre-maxwell
gov.uscourts.nysd.447706.993.0
28 pg
…Dkt. 991, and states as follows.
INTRODUCTION
Of the nine categories of documents that the parties agreed upon for purposes of the Court’s
unsealing analysis, Maxwell concedes that eight consist of “judicial documents,” 1 Dkt. 991 at 2,
which…
giuffre-maxwell
gov.uscourts.nysd.447706.370.0
17 pg
…Requests, attached to Declaration of Laura
Menninger (“Menninger Decl.”) as Ex. A. The documents requests cover every single aspect of
Ms. Maxwell’s personal life and finances from 2015 to present, including all documents “related
to” her:
tax returns…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.19
17 pg
…Requests, attached to Declaration of Laura
Menninger (“Menninger Decl.”) as Ex. A. The documents requests cover every single aspect of
Ms. Maxwell’s personal life and finances from 2015 to present, including all documents “related
to” her:
tax returns…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…the
journalist is called upon, as other citizens, to testify with respect to personal observations”
1 As discussed in detail below, the undersigned has informed Churcher’s counsel that the Subpoena is not intended
to cover any information from confidential…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.11
8 pg
…and immaterial and has
2
WITNESS DIRECf CROSS REDIRECT RECROSS
2 no probative value with regard to this
3 particular witness based up
giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…fact, seeking
only to response Plaintiff on one subject: “Defendant should be ordered to sit for a follow-up
deposition and directed to answer questions regarding her knowledge of alleged “adult” sexual
activity.” Plaintiff’s Motion to Compel Deposition Questions…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.4
106 pg
…Q. Did you ever bring someone who was
11 areas. I will leave it up to you, but 11 under -- invite someone under the age of 18
12 if this is general background it will 12 to Jeffrey's home…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.5
465 pg
…fine.
9 I assumed by your first question
10 you were going into more sensitive
11 areas. I will leave it up to you, but
12 if this is general background it will
13 not be designated as confidential.
14 …
giuffre-maxwell
gov.uscourts.nysd.447706.1335.1
465 pg
…fine.
9 I assumed by your first question
10 you were going into more sensitive
11 areas. I will leave it up to you, but
12 if this is general background it will
13 not be designated as confidential.
14 …
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