giuffre-maxwell
gov.uscourts.nysd.447706.1046.0
3 pg
…NY 10007
Re: Giuffre v. Maxwell,
Case No. 15-cv-7433-LAP
Dear Judge Preska,
Plaintiff writes pursuant to the Court’s instructions during the March 31, 2020 telephone
conference, to identify the first five motions for the unsealing process…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
…Non-party Sarah Ransome, by and through her undersigned counsel, hereby submits this
Motion for a Protective Order based on harassing and highly personal discovery sought by
subpoena and during her deposition.
BACKGROUND
On February 6, 2017, Defendant served non…
giuffre-maxwell
gov.uscourts.nysd.447706.1210.0_1
3 pg
…adults and testimony and identifying information
of non-party Does who have not been considered for unsealing,
the Court considered, as it did during the last round of
unsealing, the reliance of these parties on the case’s
protective order.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1100.1
13 pg
… The Discovery disclosed to the defendant
(“Defendant”) and/or to the defendant’s criminal defense
attorneys (“Defense Counsel”) during the course of proceedings
in this action:
a) Shall be used by the Defendant or her
Defense Counsel solely for purposes…
giuffre-maxwell
gov.uscourts.nysd.447706.1353.0
6 pg
…respectfully moves to unseal—in a limited fashion—various
materials previously produced by the law firm of Boies Schiller Flexner LLP to the Government
pursuant to a Grand Jury subpoena (the “Materials”) during the grand jury investigation of Jeffrey
Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,
during her second deposition, Defendant again refused to answer numerous questions regarding
sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the
…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…LAP Document 1078-5 Filed 07/29/20 Page 6 of 161
Socialite Ghislaine Maxwell 'groped a 16-year-old girl
during a naked massage,' victims' lawyer says
dailymail.co.uk/news/article-8163681/Socialite-Ghislaine-Maxwell-groped-16-year…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.36
10 pg
…At that deposition, he
asserted his Fifth Amendment privilege and declined to answer all substantive questions posed to
him during the deposition. The validity of his assertion of the privilege has already been the subject
of extensive litigation in this…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,
during her second deposition, Defendant again refused to answer numerous questions regarding
sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the
…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,
during her second deposition, Defendant again refused to answer numerous questions regarding
sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the
…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.1_1_1_1
10 pg
…counsel, hereby files this
Motion to Compel Defendant to Answer Deposition Questions. During her recent deposition,
Defendant refused to answer numerous questions about allegedly ·'adult'' sexual activity related
to Jeffrey Epstein. Because this activity is highly relevant to this case…
giuffre-maxwell
gov.uscourts.nysd.447706.143.0
10 pg
…counsel, hereby files this
Motion to Compel Defendant to Answer Deposition Questions. During her recent deposition,
Defendant refused to answer numerous questions about allegedly “adult” sexual activity related
to Jeffrey Epstein. Because this activity is highly relevant to this case…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.1
17 pg
…2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,
during her second deposition, Defendant again refused to answer numerous questions regarding
sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the
…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.4
6 pg
…me.
We were serving subpoenas on dates that we thought are grouped within the locations/date ranges we discussed during
the meet and confer and since we have been having an extraordinarily difficult time serving witnesses who appear to be…
giuffre-maxwell
gov.uscourts.nysd.447706.363.9
5 pg
…made against me, it concludes that in Judge Freeh’s professional opinion, “The
totality of the evidence found during the investigation refutes the allegations made against
Professor Dershowitz.”
STATEMENT OF LOUIS J. FREEH
Over the past several months, an independent…
giuffre-maxwell
gov.uscourts.nysd.447706.18.0
5 pg
…hereby respectfully submits this Memorandum of Law in
support of her Motion to Stay Discovery during the pendency of her Motion to Dismiss.
LEGAL STANDARD
Rule 26(c) of the Federal Rules of Civil Procedure grants courts broad discretion to…
giuffre-maxwell
1320-2
10 pg
…and through her undersigned counsel, hereby files this
Motion to Compel Defendant to Answer Deposition Questions. During her recent deposition,
Defendant refused to answer numerous questions about allegedly .. adult'' sexual activity related
to Jeffrey Epstein. Because this activity is highly…
giuffre-maxwell
gov.uscourts.nysd.447706.908.0
4 pg
…In 2011, the Federal Bureau of Investigation (“FBI”) met with Plaintiff Virginia Giuffre
at the United States Consulate in Sydney, Australia. During that meeting, Plaintiff informed FBI
Special Agents of the existence of multiple original photographs. See Edwards Declaration, FBI…
giuffre-maxwell
gov.uscourts.nysd.447706.685.0
6 pg
…attorneys, Paul Cassell and Brad Edwards, during the trial.
This is a transparent ploy to attempt to disrupt Ms.
Giuffre’s legal team and should be precluded.
FACTUAL BACKGROUND
In the upcoming four-week trial of this matter, Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…DOC 291 thoroughly outlines: (1) The relationship
between Dershowitz and Epstein; (2) Dershowitz's role representing Epstein during the criminal
investigation of Epstein; (3) Dershowitz's role in negotiating the Non-Prosecution Agreement
("the NPA") between Epstein and the United…
Comments