giuffre-maxwell
gov.uscourts.nysd.447706.944.0
11 pg
…Miami
Herald claims to practice. Indeed none of the descriptions of alleged sexual activities or
unsupported claims of sex with nonparties would be relevant to the Herald’s claimed
investigation of a “cross-border sex-trafficking ring,” Mot. to Unseal…
giuffre-maxwell
gov.uscourts.nysd.447706.936.0
21 pg
…21
and to witnesses who may be able to provide evidence of a wider, cross-border sex-trafficking
ring.
In connection with its ongoing investigation, the Miami Herald has sought to access public
court filings that will shed light on…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…from the deposition
testimony of a deceased individual, who Ms. Maxwell never had the opportunity to cross-
examine, and who (contemporaneous with his deposition) was convicted of a felony and
sent to prison for stealing, and then trying to sell…
giuffre-maxwell
gov.uscourts.nysd.447706.988.1
5 pg
…02-17-2017 Defendant’s Objections to Plaintiff's Cross Designations................................................ 8
03-28-2017 Response to Defendant’s Objections to Plaintiff's Designations...................................... 9
03-28-2017 Notice of filing Typographical Errors..................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.988.0_2
6 pg
…02-17-2017 Defendant’s Objections to Plaintiff's Cross Designations................................................ 8
03-28-2017 Response to Defendant’s Objections to Plaintiff's Designations...................................... 9
03-28-2017 Notice of filing Typographical Errors..................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.3
21 pg
…1987) (where attorney took stand, privilege
waived for information necessary to cross-examine attorney).
To be sure, parts of Barden’s Declaration appear to have been cleverly written in an
attempt obscure the fact that he is revealing attorney-client…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.28_4
5 pg
…action pertaining to JE
Every story in the press innuendo and comment has been taken from civ
depositions against JE, which were settled many years ago. None of the
depositions were ever subject to cross examination, not one. any I
…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.7
11 pg
…Ms. McCawley, to
18 allow Mr. Scarola a couple questions on
19 examination on cross and then my ruling is going
20 to be as follows: You can go ahead and ask
21 whatever questions you want, Mr. Scarola, at…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.6
134 pg
…383 South University Street BY MR. CASSELL:
Salt Lake City, Utah 84112 5
5 Phone: 801.585.5202 CROSS-EXAMINATION 275
6 BY MR. PAGLIUCA:
…
giuffre-maxwell
gov.uscourts.nysd.447706.1338.1
134 pg
…383 South University Street BY MR. CASSELL:
Salt Lake City, Utah 84112 5
5 Phone: 801.585.5202 CROSS-EXAMINATION 275
E-mail: [email protected] 6 BY MR. PAGLIUCA:
…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…motion papers. And Maxwell cites no
precedent for the proposition that Doe 1’s memory is a countervailing interest sufficient to justify
continued sealing—Doe 1’s medical condition may have been the proper subject of
cross-examination, but it…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…innuendo and comment has been taken from civil
depositions against JE, which were settled many years ago. None of the
depositions were ever subject to cross examination, not one. Any standard of
truth and were used for those who claimed…
giuffre-maxwell
gov.uscourts.nysd.447706.1062.0
7 pg
…of a protective order, regardless of whether a party
later seeks – or acquiesces to – the release of that information. Those non-parties “have a right
to be protected against becoming victims of litigation cross-fire.” Minpeco, S.A. v.
Conticommodity…
giuffre-maxwell
gov.uscourts.nysd.447706.1067.0
10 pg
…There is no support for Ms. Maxwell’s claims that the third-party depositions are
unreliable. She simply claims that her counsel did not cross-examine the witnesses under
oath. But this is the hearsay standard, not the sealing standard…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.8
10 pg
…05/24 Page 5 of 10
content of that email, a communication with a key witness, nor did she have the opportunity to
use it to cross some of Defendant’s evasive answers. Additionally, due to the late production,
Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.563.0
10 pg
…no need to resort to such recorded testimony. Ms.
Giuffre will appear at trial at testify during her case-in-chief and, of course, be cross-examined
by defense counsel. In addition, Ms. Giuffre will be available to be a…
giuffre-maxwell
gov.uscourts.nysd.447706.135.0
37 pg
…Y.C.P.L.R. § 4503(a) (1).
The privilege only appli es to attorney-client
communications "primarily or predominately of a l ega l
ch aracter." Hossi v. Blue Cross & Blue Shi.el.?..._C?l._..S:;r ~_
giuffre-maxwell
1320-28
32 pg
…innuendo and comment has been taken from civil
depositions against JE, which were settled many years ago. None of the
depositions were ever subject to cross examination, not one. Any standard of
truth and were used for those who claimed…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.19_2
32 pg
…innuendo and comment has been taken from civil
depositions against JE, which were settled many years ago. None of the
depositions were ever subject to cross examination, not one. Any standard of
trnth and were used for those who claimed…
giuffre-maxwell
gov.uscourts.nysd.447706.88.0
7 pg
…appear to vouch for his own
credibility, (2) the lawyer’s testimony will put opposing counsel in a difficult position when he
has to vigorously cross-examine his lawyer-adversary and seek to impeach his credibility, and
(3) there may…