giuffre-maxwell
gov.uscourts.nysd.447706.1122.0_2
13 pg
…thereto.
INTRODUCTION
The USVI seeks confidential access to these materials because they are very likely both
relevant and necessary to its pending Virgin Islands Criminally Influenced and Corrupt
Organizations Act (“CICO”) civil enforcement action against the Estate of Jeffrey E…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…Order.
The USVI seeks confidential access to these sealed documents and unfiled discovery
materials because they are very likely relevant to its pending Virgin Islands Criminally
Influenced and Corrupt Organizations Act (“CICO”) enforcement action against the Estate of
Jeffrey E…
giuffre-maxwell
gov.uscourts.nysd.447706.205.0
7 pg
…file a motion to quash a subpoena served on a third party when the party has a
personal right or privilege regarding the subject matter of the subpoena. See, e.g., Estate of
Ungar v. Palestinian Authority, 332 Fed. Appx…
giuffre-maxwell
gov.uscourts.nysd.447706.370.0
17 pg
…Id.at RFP 25, 27, 28, 29, 30, and 31.
real estate or personal property in which she holds an interest; Id. at RFP 20, 26, and 36.
loans or statements of indebtedness to or from Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.19
17 pg
…Id.at RFP 25, 27, 28, 29, 30, and 31.
real estate or personal property in which she holds an interest; Id. at RFP 20, 26, and 36.
loans or statements of indebtedness to or from Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1118.0
21 pg
…and Defendant Ms. Maxwell. The
Government contends that intervention will assist in its action to enforce the Virgin Islands
Criminally Influenced and Corrupt Organizations Act (“CICO”) against the Estate of Jeffrey E.
Epstein. The Estate of Jeffrey E. Epstein is…
giuffre-maxwell
gov.uscourts.nysd.447706.207.0
7 pg
…file a motion to quash a subpoena served on a third party when the party
has a personal right or privilege regarding the subject matter of the subpoena. See, e.g., Estate of
Ungar v. Palestinian Authority, 332 Fed. Appx…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…d] that
plaintiff’s current requests for financial discovery are overbroad.” Id. at 4. There the Plaintiff
sought “three years of tax returns; information regarding real estate holdings, motor vehicles,
investments, and bank and brokerage accounts; documents regarding personal loans…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…is seeking to drain funds from the very estate that should be paying the
Epstein victims’ claims...We view her actions as unconscionable but this is an individual who lost
sight of right from wrong a very long time ago…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…participated in this sex trafficking scheme is a matter of public
concern.
TGP cannot conduct its Fourth Estate function if this Court allows the worst criminals to
hide in the shadows outside of the normal sunlight of transparency and accessibility…
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…see infra at 7, because of their potential
relevance to its pending Virgin Islands Criminally Influenced and
Corrupt Organizations Act (“CICO”) enforcement action against the
Estate of Jeffrey E. Epstein and several Epstein-controlled
entities before the Superior Court of…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.10
64 pg
…to intervene for
2 the purposes of unsealing. My client is a member of the media.
3 The Fourth Estate has a First Amendment right to review
4 judicial documents, a common law right of access to the court
5…
giuffre-maxwell
gov.uscourts.nysd.447706.551.0
17 pg
…citizens in the discussion of these problems. Cernovich Media cannot conduct
its Forth Estate function if this Court allows the Parties to conduct their dispute outside of the
normal sunlight of transparency and accessibility. The public has a right to…
giuffre-maxwell
gov.uscourts.nysd.447706.22.0
14 pg
…12, 1985)
(denying motion to stay where moving party made only conclusory statements to establish good cause).
5
Case 1:15-cv-07433-RWS Document 22 Filed 12/15/15 Page 8 of 14
real estate purchases, living expenses…
giuffre-maxwell
gov.uscourts.nysd.447706.702.0
63 pg
…to intervene for
2 the purposes of unsealing. My client is a member of the media.
3 The Fourth Estate has a First Amendment right to review
4 judicial documents, a common law right of access to the court
5…
giuffre-maxwell
gov.uscourts.nysd.447706.371.2
18 pg
…or other vessels of any type
d. Real estate and real property
RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad
and unduly burdensome and calls for the production of documents that are irrelevant…
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