giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…Rules of Civil Procedure and
(2) should intervention be permitted, for confidential access to
sealed judicial records and discovery documents. (See Notice of
Ex Parte Motion to Intervene and for Confidential Access to
Documents, dated Sept. 1, 2020 [dkt. no…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…Media Company ("Miami
Herald"), Intervenors in the above-captioned case, hereby appeal to the United States Court of
Appeals for the Second Circuit from the Memorandum and Order dated August 24, 2018, and
entered in this action on August 27…
giuffre-maxwell
gov.uscourts.nysd.447706.1158.0
17 pg
…York
500 Pearl Street
New York, NY 10007
Re: Giuffre v. Maxwell,
Case No. 15-cv-7433-LAP
Dear Judge Preska,
Pursuant to the Court’s order dated November 20, 2020 (ECF No. 1157), and in light of
Does 1…
giuffre-maxwell
gov.uscourts.nysd.447706.15.0
29 pg
…Laura A. Menninger, Esq.
HADDON, MORGAN AND FOREMAN, P.C.
150 East 10th Avenue
…
giuffre-maxwell
gov.uscourts.nysd.447706.40.0
8 pg
…to sit for her deposition. See McCawley
Decl. at Exhibit 3, (E-mail from Laura Menninger stating: “We have not and will not accept the
date of March 25, or any other date, for Ms. Maxwell’s deposition until a…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.32
4 pg
…details of his person and the sex
acts and can describe th.em in the event it becomes necessary to do so.
I affirm under penalty of perjury that the foregoing is true and correct.
Dated: (JS - 0 l - .' 20 …
giuffre-maxwell
gov.uscourts.nysd.447706.1258.0
3 pg
…1:15-cv-07433-LAP Document 1258 Filed 07/28/22 Page 2 of 3
PLEASE TAKE NOTICE that opposition papers, if any, shall be served in accordance with
Local Civil Rule 6.1.
Dated: July 28, 2022. Respectfully Submitted,
…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.1_1
13 pg
…police reports, most
identifying Ms. Giuffre as a victim. However, the date-stamps on these documents, marking when
Defendant received them, were dated in April of 2016.1 In other words, Defendant received those
reports after the March 21, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.751.12
3 pg
…to the 31-year-old say she relished her role as his 'travelling masseuse' and never
acted like she was being held captive.
Philip Guderyon, who used to date Roberts and would drive her to Epstein's Pal Beach, Florida…
giuffre-maxwell
gov.uscourts.nysd.447706.751.10
4 pg
…The prince is accused of having sex with the woman when she was 17, details of which are is a sworn affidavit in
Florida court dated January 19. The woman said that she and the Prince had sex "three times…
giuffre-maxwell
gov.uscourts.nysd.447706.29.0
2 pg
…arguments advanced by Ms. Maxwell in support of
her Motion to Dismiss. Ms. Maxwell therefore respectfully requests that the Court take notice of
this supplemental authority.
Dated: January 22, 2016.
Respectfully submitted,
s/ Laura…
giuffre-maxwell
gov.uscourts.nysd.447706.26.0
3 pg
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAIINTIFF, VIRGINIA L. GIUFFRE’S NOTICE OF SUPPLEMENTAL AUTHORITY
In furt…
giuffre-maxwell
gov.uscourts.nysd.447706.185.8
24 pg
…Second Set of Document Requests and Cassell’s Objection to Request No. 2 in
Response to Dershowitz’s Third Set of Document Requests, per Dershowitz’s Amended Notice
of Hearing dated September 10, 2015. Plaintiffs served these additional discovery responses
…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…have offered to make available to Dershowitz's
counsel for inspection. vAs of today's date Plaintiffs have produced all documents which are
properly subject to discovery in this action, either by producing a copy directly to Dershowitz or
identifying…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.22_1
10 pg
…false
misrepresentations to the Court that Plaintiff included within her Reply, if Plaintiff does not
honor her obligations under Rule of Professional Conduct 3.3 to withdraw them of her own
accord.
Dated: August 25, 2016.
Respectfully submitted,
…
giuffre-maxwell
gov.uscourts.nysd.447706.69.2
21 pg
…not less than $50,000,000.00.
a. This calculation is in the province of the jury.
18
Case 1:15-cv-07433-LAP Document 69-2 Filed 03/23/16 Page 20 of 21
Dated March 11, 2016
…
giuffre-maxwell
gov.uscourts.nysd.447706.363.6
15 pg
…Dershowitz, which support and/or confirm the allegations set forth in
Paragraphs 24-31 of your Declaration dated January 19, 2015 and/or Paragraph 49 of your
8
Case 1:15-cv-07433-LAP Document 363-6 Filed 08…
giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…2
Following Brown, minimal redactions have been applied to (1) “personally identifying
information such as personal phone numbers, contact lists, birth dates, and social security
numbers”; (2) “the names of alleged minor victims of sexual abuse”; and (3) “deposition responses…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.8
16 pg
…would have
argued until the matter came too late. The motion is proper at this time because, as of the date of
this filing, fact discovery closes in 17 days (although Ms. Giuffre has recently filed a motion for
a…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…depositions in this action.
CONCLUSION
For all of the foregoing reasons, the USVI respectfully moves this Court to GRANT the
Ex Parte Motion to Intervene and for Access to Judicial Records and Discovery Documents.
Dated: September 1, 2020
…
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