Found 32 results for “cover up” in 384ms

gov.uscourts.nysd.447706.43.0.pdf PDF

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…

gov.uscourts.nysd.447706.53.0.pdf PDF

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…

gov.uscourts.nysd.447706.824.0_2.pdf PDF

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 …

gov.uscourts.nysd.447706.993.0.pdf PDF

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…

gov.uscourts.nysd.447706.1201.10_1.pdf PDF

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…

gov.uscourts.nysd.447706.1335.4.pdf PDF

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…

gov.uscourts.nysd.447706.1307.5.pdf PDF

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 …

gov.uscourts.nysd.447706.1335.1.pdf PDF

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 …

gov.uscourts.nysd.447706.31.0_1_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.31.0_1_1 22 pg

…the scope of the litigation or to negotiate 19 a resolution in advance of litigation. That prelitigation 20 privilege does not cover public statements by Ms. Maxwell's 21 hired press agent that are given to the national and 22…

gov.uscourts.nysd.447706.1327.26.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1327.26 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…

gov.uscourts.nysd.447706.1330.23.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1330.23 9 pg

…to confer with Defendant to secure her agreement to be deposed on this new information, Defendant refused to sit for a follow up deposition (despite the fact that Ms. Giuffre agreed to sit for her deposition under these same circumstance)…

gov.uscourts.nysd.447706.1137.13_5.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1137.13_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 …

gov.uscourts.nysd.447706.1325.18.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1325.18 23 pg

…the scope of the litigation or to negotiate 19 a resolution in advance of litigation. That prelitigation 20 privilege does not cover public statements by Ms. Maxwell's 21 hired press agent that are given to the national and 22…

gov.uscourts.nysd.447706.1201.19.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1201.19 106 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…

gov.uscourts.nysd.447706.1320.6.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1320.6 10 pg

…Defendant’s sexual relationship with Epstein from 1992 to 2009 – the time period in which she worked for Jeffrey Epstein and which Epstein (with the assistance of Defendant) was engaging in sexual acts with females under the cover of “massage”…

gov.uscourts.nysd.447706.20.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.20.0 26 pg

…statement from house employee Juan Alessi in which he revealed that girls would come over to give “massages” and he observed Ms. Maxwell going upstairs in the direction of the bedroom quarters. See Decl. of Sigrid McCawley at Exhibit 7…

gov.uscourts.nysd.447706.23.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.23.0 32 pg

…to bully the victim back into silence. But this story will not end here. Defamation law protects victims when they are courageous enough to stand up against their abuser’s false character assaults. Based on her well-pled Complaint, Ms…

gov.uscourts.nysd.447706.99.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.99.0 22 pg

…motives, and character into question by virtue of her claims in this lawsuit, Plaintiff must be prepared to cough up any evidence – or more likely, contradictory evidence – that she and her 15 attorneys’ have spent the last 5 years of…

1320-6.pdf PDF

giuffre-maxwell 1320-6 10 pg

…Defendant’s sexual relationship with Epstein from 1992 to 2009 – the time period in which she worked for Jeffrey Epstein and which Epstein (with the assistance of Defendant) was engaging in sexual acts with females under the cover of “massage”…

gov.uscourts.nysd.447706.45.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.45.0 17 pg

…explanation for her expansive time frame as discussed below. The gist of Plaintiff’s temporal relevance argument is that, according to Plaintiff, Ms. Maxwell communicated or associated with Mr. Epstein after 2002 up to 2015. And, according to Plaintiff, Mr…

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