…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…
…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. …
… 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…
…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…
…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…
…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…
…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…
…21 Page 3 of 10 Case 1:15-cv-07433-LAP Document 1199-22 Filed 01/27/21 Page 4 of 10 Q. Do you know what happened during the massage appointments with Jeffrey Epstein and Virginia Roberts? A…
…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 …
…bunch of photographs. I have looked at them, 11 nothing prurient about them, they all predate the statute of 12 limitations time period and were used during the deposition. 13 THE COURT: Yes, but generically I am correct, am I…
…Q. Tatts, right. 13 But the 17 individuals that you listed in 14 Exhibit 1, none of those individuals ever said the 15 word -- the words "Ghislaine Maxwell" during the 16 course of this investigation to you, correct? 17 MS…
…approaching 13 hours on the record, far more than the presumptive 7 hour limit under the Federal Rules. During that time, Plaintiff has had a full and fair opportunity to depose Ms. Maxwell on the subject matters she claims are…
…to answer certain questions at her deposition and (2) her late production of important emails. These two issues developed as follows. Defendant’s Failure to Answer Certain Questions During her first deposition, Defendant improperly refused to answer certain questions. Accordingly…
…from 2000 - 2002. Defendant has denied that she used those accounts to communicate, but she has not disclosed the account she did use to communicate during that time, nor produce documents from it. Case 1:15-cv-07433-LAP…
…a set of redactions from Ms. Maxwell’s counsel other than a few examples she provided via phone during our meet and confer of areas of testimony where she contended there should be additional redactions. We await the Court’s…
… 15 A. I helped out from time to time. 16 Q. So you were working with him during 17 the time period when these underage girls 18 were visiting Jeffrey's home? 19 MR. PAGLIUCA: Objection to the 20 form…
…thus any reply currently is due November 27. That day is the day after Thanksgiving. Because defense counsel’s office is scheduled to be closed for the holiday weekend during that period of time, we request a brief two (2…
…thus any reply currently is due November 27. That day is the day after Thanksgiving. Because defense counsel’s office is scheduled to be closed for the holiday weekend during that period of time, we request a brief two (2…
…as a minor, even though the video had been played publicly for the jury in the underlying trial, and even though a transcript of his statements during that deposition remained publicly available during and after the trial. Id. at 55…
…8 Q. So did you have - - did you give a 9 massage with Virginia Roberts and Mr. Epstein 10 during the first time Virginia Roberts was at 11 the West Palm Beach house? 12 MR. PAGLIUCA: Object to the form…
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