giuffre-maxwell
gov.uscourts.nysd.447706.1332.15
11 pg
…to Dismiss in the matter
before Judge Koeltl. The Epstein Defendants argue that the materials can be used to establish
that Jane Doe 43’s claims should be barred because they are outside the ten (10) year statute of
limitation…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…and information, including without limitation,
documents produced, answers to interrogator ies, responses to
requests for admission, deposition testimony, and other
information disclosed pursuant to the disclosure or discovery
duties created by the Federal Rules of Civil Procedure." Id. 'IT
1…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…potions, discussed below, is
met – the information is highly relevant, critical to the defense, and available form no other source.
5
Case 1:15-cv-07433-LAP Document 1325-1 Filed 01/04/24 Page 8 of 21
C…
giuffre-maxwell
gov.uscourts.nysd.447706.436.0
15 pg
…9
Rules & Statutes
Civil Rights Law § 79-h(c) ............................................................................................................. 9
Fed. R. Civ. P. 26 ...................................................................................................................... 9, 10
…
giuffre-maxwell
gov.uscourts.nysd.447706.364.0
32 pg
…errors.
7
8
x
9
x
x
x
x
x
10
ARGUMENT
I. PROFESSOR DERSHOWITZ SHOULD BE PERMITTED TO INTERVENE
UNDER FEDERAL RULE OF CIVIL PROCEDURE 24(B)
“On timely motion, the court…
giuffre-maxwell
gov.uscourts.nysd.447706.78.0
30 pg
…Filed 04/04/16 Page 5 of 30
Wachtman v. Trocaire College,
532 N.Y.S.2d 943(N.Y. App. Div. 998)....................................................................................18
Statutes
S.D.N.Y. Local Rule 33.3......................................................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.370.0
17 pg
…in many actions (including
actions for double and treble damages authorized by various statutes), it is readily
seen that a rule permitting unlimited examination before trial of a defendant as to
his wealth in a punitive damage action could have…
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
…should be dismissed.
25 Our papers go on a little bit further, your Honor, to
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 31 Filed 01/28/16 Page 6 of 22…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.18
23 pg
…be dismissed.
25 Our papers go on a little bit further, your Honor, to
SOUTHERN DISTRICT REPORTERS, P.C .
(212) 805-0300
Case 1:15-cv-07433-LAP Document 1325-18 Filed 01/04/24 Page 7 of 23…
giuffre-maxwell
gov.uscourts.nysd.447706.20.0
26 pg
…And, like the self-defense
privilege, at the motion to dismiss stage, the privilege disappears in the face of a well-pleaded
allegation that the statement is not pertinent to a good faith anticipated litigation and, instead, the
Defendant has…
giuffre-maxwell
gov.uscourts.nysd.447706.435.0
27 pg
…order by truthfully answering a question put to me by the opposing lawyer and
offering to seal my answer. The BSF motion for sanctions was subsequently dismissed for lack of jurisdiction and
standing, and is now being appealed by Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.3_2
12 pg
Case 1:15-cv-07433-LAP Document 1150-3 Filed 11/12/20 Page 1 of 12
EXHIBIT C
Case 1:15-cv-07433-LAP Document 1150-3 Filed 11/12/20 Page 2 of 12
Google Results - ghislaine…
giuffre-maxwell
gov.uscourts.nysd.447706.851.0
158 pg
…called)
2 THE COURT: Like all of you, you woke up in the middle
3 of the night thinking about this case. I would like to see if
4 I can clarify my understanding.
5 In the motion to dismiss…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.11
9 pg
…As discussed in our response (Doc.653) the failure to comply with the rules is an
independent ground for denial of a motion to compel. Plaintiff tries in her reply to fix the rules
violations, but there are some procedural…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…and she cites the same countervailing interests discussed in Part IV, supra.
Maxwell Mem. at 8. For the same reasons explained above, she has failed to state with specificity
why the portions of this document that mention no Non-Party…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…Rule 37(b) of the Federal Rules of Civil Procedure provides
that the court may impose a range of sanctions, including dismissal or judgment by default,
preclusion of evidence, imposition of an adverse inference, or assessment of attorneys' fees and…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.30
40 pg
…15 A. I think roughly October.
16 Q. Of what year?
17 A. 2005.
18 Q. Why?
19 A. My wife and I had discussed these
20 incidents, and this last one was just, we
21 couldn't deal with…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…of 21. Basically trying to
dirty the victim as much as possible.”
15
Dershowitz says that he “loudly” proclaimed his innocence, but he also attacked Professor Cassell and Ms.
Edwards. Dershowitz also repeatedly and publicly attacked Ms. Giuffre, as discussed…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.22
40 pg
…15 A. I think roughly October.
16 Q. Of what year?
17 A. 2005.
18 Q. Why?
19 A. My wife and I had discussed these
20 incidents, and this last one was just, we
21 couldn't deal with…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…179:16 -184:15
titled “Massage – Florida” from an address book
marked in the first deposition and discussed at
length
THE QUESTIONS
I. PLAINTIFF’S FAILURE TO IDENTIFY THE SPECIFIC QUESTIONS
CLAIMED UNANSWERED REQUIRES DENIAL OF THE MOTION
Plaintiff broadly…
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