…Maxwell’s sexual activities. Ultimately the Court created the boundaries of discoverable matters and at the parties’ request entered a protective order that allowed the parties to provide discovery on highly private and sensitive subjects that could not be disclosed…
…the issues; documents that are not relevant to any party’s claim or defense; and documents that are not proportional to the needs of the case. Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such…
…of supporting evidence.2 Instead, according to Dershowitz, these materials create some sort of a web of circumstantial inferences suggesting his innocence. His attenuated reasoning hardly provides the kind of compelling reason needed to pierce the Protective Order. Instead, Dershowitz…
…that the court file, which includes only some of the documents created during discovery, totals in the “thousands of pages”). Giuffre sought and obtained a wide variety of private and confidential information about Maxwell and others, including information about financial…
…memoranda, witness interviews, and other material’” created in preparation for litigation and trial (emphasis added) (internal citation omitted)). Indeed, “protection of witness interviews has been one of the focuses of the attorney 21 relevance of the questions were tenuous at…
…MENNINGER: Your Honor, on this particular one, 6 she says her client does not have any nonprivileged documents 7 created during the time period responsive to this request, and 8 then there are no privileged documents related to this log…
…memoranda, witness interviews, and other material’” created in preparation for litigation and trial (emphasis added) (internal citation omitted)). Indeed, “protection of witness interviews has been one of the focuses of the attorney 21 relevance of the questions were tenuous at…
…or documents concerning any police reports, that were created concerning such claims of sexual assault; and (3) documents concerning any communications received by You (or Your agents or attorneys) by other individuals that reference any sexual assault of Plaintiff while…
…Defendant’s documents concerning Ms. Giuffre are directly relevant to this action, particularly because Defendant has created multiple drafts of statements to the press defaming Ms. Giuffre. Throughout the months of motion practice concerning these issues, and throughout all of…
…MENNINGER: Your Honor, on this particular one, 6 she says her client does not have any nonprivileged documents 7 created during the time period responsive to this request, and 8 then there are no privileged documents related to this log…
…the purported trafficking scheme that the USVI is investigating in the CICO action, as he allegedly “created and directed the companies whose aircraft transported the young women and girls, owned and maintained the secluded islands to which they were transported…
…71 F.3d 1044, 1048 (2d Cir. 1995). Both the First Amendment and common law rights of access create a presumption against secrecy for “judicial documents.” See Newsday, 730 F.3d at 164 (First Amendment); Amodeo I, 44 F.3d…
…details about Giuffre's sexual abuse and listed the perpetrators of her abuse. Giuffre repeatedly named Maxwell in the Joinder Motion as being personally involved in the sexual abuse and sex trafficking scheme created by Epstein. On January 3, 2015…
…attorney competencies belies this statement.2 First, it is expected that the overwhelming majority of documents “concerning” Ms. Giuffre are attorney-client communications or work product created after the filing of this lawsuit. Such documents do not even require extensive…
…Counsel for Ms. Giuffre stated that she would obtain a signature page. Pursuant to that agreement, Ms. Giuffre’s Counsel created a Declaration, sent it to Ms. Giuffre, whereupon she executed it. The Declaration was served upon Defendant. This is…
…The defense intends to show that Plaintiff for financial and other improper reasons manufactured her allegations of “sex trafficking” and created from whole cloth her alleged $30 million in noneconomic damages from “defamation.” Some of the most relevant and material…
…raising questions about the credibility of crime victims that the Government apparently does not intend to present. 8 Allowing his intervention would thus create a clear risk of adding undue delay to what is already a long-running case. Cf…
…ARGUMENT A. The USVI Has Compelling Need for Access to Jeffrey Epstein’s and Other Witnesses’ Depositions. The USVI alleges in its CICO action that Epstein created and participated in a criminal sex trafficking enterprise in the Virgin Islands, wherein…
…or documents concerning any police reports, that were created concerning such claims of sexual assault; and (3) documents concerning any communications received by You (or Your agents or attorneys) by other individuals that reference any sexual assault of Plaintiff while…
…of supporting evidence.2 Instead, according to Dershowitz, these materials create some sort of a web of circumstantial inferences suggesting his innocence. His attenuated reasoning hardly provides the kind of compelling reason needed to pierce the Protective Order. Instead, Dershowitz…
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