giuffre-maxwell
gov.uscourts.nysd.447706.24.3
3 pg
…Sun, Jan 4, 2015
Ghislaine Maxwell: ‘I was not a madam
for paedophile’
SOCIALITE Ghislaine Maxwell dismissed claims yesterday that she
acted as a “madam” to supply underage girls to US businessman
Jeffrey Epstein.
PUBLISHED: 00:10, Sun, Jan 4…
giuffre-maxwell
gov.uscourts.nysd.447706.962.0
7 pg
…Order.
INTRODUCTION
The Protective Order requires the destruction or return of all “Confidential”-designated
materials. This action was terminated more than eighteen months ago when the parties reached a
settlement and stipulated to dismissal, and the Court dismissed the case…
giuffre-maxwell
gov.uscourts.nysd.447706.116.0
6 pg
…statements, that will do it.
…
MR. EDWARDS: Sure. … There are two ways in which a case can be dismissed in
Florida. One is by way of a court order. The other is by way of a stipulation. That…
giuffre-maxwell
gov.uscourts.nysd.447706.29.1
18 pg
…Plaintiff in a false light, and (3) Defendant intentionally inflicted emotional distress upon
Plaintiff.1 Presently before the Court is a Motion to Dismiss and Brief in Support filed by
Defendant alleging that no justiciable claim or controversy exists. Doc…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.1
18 pg
…this has been Defendant’s strategy, and the Court should not
accept such stonewalling as a litigation tactic.
In the Second Circuit, courts have dismissed actions where a party has demonstrated
willful disregard for its discovery obligations. Edwards v. Am…
giuffre-maxwell
gov.uscourts.nysd.447706.965.0
9 pg
…much to everyone's happiness, including the Court's,
14 and was dismissed shortly thereafter. Two times since May we
15 have asked for agreed upon protocol with the plaintiff's
16 counsel to finish up destroying or exchanging-back…
giuffre-maxwell
gov.uscourts.nysd.447706.2.0
2 pg
…SONY at any time? Nfiles0iudge Previously Assigned
If yes, wa s this case Vol. D In vol. D Dismissed . No D Yes D If yes, give d a t e - - - - - -- - -- & Ca se No . .
Is THIS AN INTERNATIONAL ARBlT RATION CASE! …
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…2015 WL 4610422 (S.D.N.Y. July 23, 2015) (granting in part
motion to compel production).
In the Second Circuit, courts have dismissed actions where a party has demonstrated
willful disregard for its discovery obligations. Edwards v. Am. Airlines…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…
f. the disposition of any case associated with any such Communication,
irrespective of whether the matter was sealed, expunged or later dismissed.
Response to Interrogatory No. 4
Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…2016. (Doc. #13) On November 30, 2015, contemporaneous with the filing
of her Rule 12(b) Motion to Dismiss, Ms. Maxwell also requested of this Court a stay of
discovery pursuant to Rule 26(c). (Doc. #17) That motion was…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.2
23 pg
…v. :
:
GHISLAINE MAXWELL,
:
:
Defendant.
:
…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…I may well do so.”
Asked if Boies has considered bringing his own defamation lawsuit against Dershowitz, Boies dismissed
the possibility, saying “almost all public debate belongs in the public field… I’m also comfortable with the
public record…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…
f. the disposition of any case associated with any such Communication,
irrespective of whether the matter was sealed, expunged or later dismissed.
Response to Interrogatory No. 4
Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.6
10 pg
…and the charges against Epstein if any. will be
dismissed.
Page2 of 7
GIUFFRE007598
…
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
…4 on behalf of the defendant Maxwell. We are the movant for the
5 purposes of today's hearing. I filed both a motion to dismiss
6 the complaint, which is based on one claim of defamation, as
7 well…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.38
8 pg
…690 So.2d 725, 729 (Fla. 4the DCA 1997) cause dismissed, (Fla. June 2,
1997) (sanctioning a party for making public discussions that took place during mediation by
striking its pleadings and dismissing the case with prejudice: " If the trial…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…
f. the disposition of any case associated with any such Communication,
irrespective of whether the matter was sealed, expunged or later dismissed.
Response to Interrogatory No. 4
Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…
f. the disposition of any case associated with any such Communication,
irrespective of whether the matter was sealed, expunged or later dismissed.
Response to Interrogatory No. 4
Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33…
giuffre-maxwell
gov.uscourts.nysd.447706.46.0
22 pg
…objections and interposing appropriate privileges are demanded by
the Rules of Civil Procedure. Plaintiff’s hyperbole regarding “stonewalling” and un-reasonable
delays in discovery should be dismissed. All of the delays could have been prevented had she
served Requests for…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.18
23 pg
…4 on behalf of the defendant Maxwell. We are the movant for the
5 purposes of today's hearing . I filed both a motion to dismiss
6 the complaint, which is based on one claim of defamation, as
7 well…