giuffre-maxwell
gov.uscourts.nysd.447706.1320.40
19 pg
…P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following
disclosures:
I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE
INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH
PARTICULARITY IN THE PLEADINGS
1. Ghislaine Maxwell
c/o Laura A. Menninger, Esq…
giuffre-maxwell
1320-40
19 pg
…P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following
disclosures:
I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE
INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH
PARTICULARITY IN THE PLEADINGS
1. Ghislaine Maxwell
c/o Laura A. Menninger, Esq…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.15
11 pg
…party may object to the designation of particular
CONFIDENTIAL INFORMATION by giving written notice to the party
designating the disputed information… it shall be the obligation of the party
designating the information as CONFIDENTIAL to file an appropriate motion
…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.23
10 pg
…Ms. Giuffre was the child victim of sexual abuse, which is undisputed.” (Reply
at 9) If there is one thing this litigation makes clear, it is heavily disputed that Ms. Giuffre was
the child victim of sexual abuse. Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.140.3
4 pg
…at issue; rather, an in camera
assessment of the disputed documents was deemed necessary to weigh whether the particular requested documents are
shielded by a public-interest privilege against disclosure of confidential communications. 4
The public interest privilege applied, in…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.2
23 pg
…Tel.
Corp., 594 F.2d 291, 295 (2d Cir. 1979). They promote “the ‘secure the just, speedy, and
inexpensive determination’ of civil disputes, by encouraging full disclosure of all evidence.” Id.
(quoting Fed. R. Civ. P. 1). “If protective orders…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…40
Korein Tillery
(http://www.americanlawyer.com/home/id=1202754670719)
$50,000 Punitive Award Given in Attorney Fee Dispute
(http://www.dailybusiness…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.1_1
13 pg
…at ¶ 8. The Order continues:
A party may object to the designation of particular CONFIDENTIAL INFORMATION by
giving written notice to the party designating the disputed information. The written notice
shall identify the information to which the objection is made…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…the Fifth. Instead, she testified
that she suffered from a series of memory lapses and could not recall many of the key issues in
dispute in this case. As a result of Defendant’s inability to remember events, a variety…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…the Fifth. Instead, she testified
that she suffered from a series of memory lapses and could not recall many of the key issues in
dispute in this case. As a result of Defendant’s inability to remember events, a variety…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…ARGUMENT
II. EDWARDS AND CASSELL ARE ENTITLED TO PARTIAL SUMMARY
JUDGMENT ON THE PENDING PRIMARY CLAIM BECAUSE THERE
ARE NO MATERIAL DISPUTED FACTS AND THE UNDISPUTED FACTS
ESTABLISH THAT DERSHOWITZ REPEATEDLY BROADCAST FALSE
AND DEFAMATORY STATEMENTS ABOUT THEM.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.35
10 pg
…Ms. Giuffre was the child victim of sexual abuse, which is undisputed.” (Reply
at 9) If there is one thing this litigation makes clear, it is heavily disputed that Ms. Giuffre was
the child victim of sexual abuse. Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…the Fifth. Instead, she testified
that she suffered from a series of memo1y lapses and could not recall many of the key issues in
dispute in this case. As a result of Defendant's inability to remember events, a variety…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.3
28 pg
…was present with Epstein and Defendant on many occasions at Epstein’s homes in New
York, Palm Beach and the USVI, and he has personal knowledge of the disputed issues in this
case
8. Ross Gow (3 ½ hours). Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…rejected exactly the same arguments that are being
made here. This Court explained that “[w]hile bifurcation may be the preferred method of
resolving disputed issues of liability and damages, as it prevents prejudice to the defendants by
keeping financial…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…rejected exactly the same arguments that are being
made here. This Court explained that “[w]hile bifurcation may be the preferred method of
resolving disputed issues of liability and damages, as it prevents prejudice to the defendants by
keeping financial…
giuffre-maxwell
gov.uscourts.nysd.447706.604.0
11 pg
…123 (2d Cir. 2006). There is no legitimate
dispute that Mr. Cernovich is a member of the media and there is no question that this case is a
matter of public interest. Plaintiff appears to think that only members of…
giuffre-maxwell
1320-10
28 pg
…the Fifth. Instead, she testified
that she suffered from a series of memory lapses and could not recall many of the key issues in
dispute in this case. As a result of Defendant’s inability to remember events, a variety…
giuffre-maxwell
gov.uscourts.nysd.447706.730.0
14 pg
…reported her allegations of sex abuse and sex trafficking to federal law
enforcement agents in 2011, well before the disputed events in this case occurred. The jury may
use that fact of a prior report to law enforcement as one…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.19_2
32 pg
…Maxwell 's deposition (which depended, among other
things, on an historic snowsto1m, a disputed protective order, Plaintiffs failure to timely produce
documents, and counsel 's conflicting calendars, all of which have been amply documented with
this Comi)4 does not…