giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…¶ 49. Once they arrived, though, they
were sexually abused, exploited, and held captive. Id.
By way of background, Epstein’s privately-owned islands in the Virgin Islands were
essential to the sex-trafficking enterprise. Little St. James is a secluded…
giuffre-maxwell
gov.uscourts.nysd.447706.541.0
10 pg
…1999. .................................... 56
2. The January 2015 statement accurately denied that Ms. Maxwell
“regularly participate[d] in Epstein’s sexual exploitation of minors” and
that “the Government knows” such fact. ..................…
giuffre-maxwell
gov.uscourts.nysd.447706.1058.1
3 pg
…to raise similar objections. Professor Dershowitz
has explained that he is prepared to abide by any applicable court order subject only to reserving
the right to seek relief from the Court as to particular items if appropriate, a right which…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…to
learn that this clash of the legal titans has been averted, preventing the allegations on all sides
from being explored in greater depth in open court.
UPDATE (4/9/2016, 10:55 a.m.): Here is the statement of…
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
…DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 31 Filed 01/28/16 Page 3 of 22 3
G1ETGIUA
1 statements that are referenced but never explained in
2 paragraphs 31 and 34?…
giuffre-maxwell
gov.uscourts.nysd.447706.1289.0
3 pg
…the scandalous
and intimate activities described in most or all of the Confidential Records.” Id. at 3. That is also
untrue. As the Court explained in its November 18, 2022, ruling, Doe 171 filed a federal lawsuit
against Julie Brown…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.43
12 pg
…or at a minimum, warrants
allowing an independent third party to conduct a forensic review of all of Defendant’s electronic data
as explained further herein.
I. DEFENDANT’S UNDISCLOSED ACCOUNT
1
Case 1:15-cv-07433-LAP Document…
giuffre-maxwell
gov.uscourts.nysd.447706.113.0
3 pg
…and because it is anticipated that confidential matters will be
discussed. Ms. Giuffre requests expedited consideration of these materials.
As the Court recalls, in her opposition to Bradley J. Edward’s pro hac vice motion,
Defendant briefly mentioned that Edwards…
giuffre-maxwell
gov.uscourts.nysd.447706.1155.0_2
13 pg
…19/20 Page 3 of 13
criminal matter, this Court held, “[a]gain, Ms. Maxwell has relied on [ipse] dixits and has not
explained how the sealed material, if released, could, as she posits, ‘inappropriately influence
potential witnesses or victims.’”…
giuffre-maxwell
gov.uscourts.nysd.447706.538.0
10 pg
…1999. .................................... 56
2. The January 2015 statement accurately denied that Ms. Maxwell
“regularly participate[d] in Epstein’s sexual exploitation of minors” and
that “the Government knows” such fact. ..................…
giuffre-maxwell
gov.uscourts.nysd.447706.1188.0
3 pg
…the Court
could take expedited briefing on DE 143 and its related pleadings and rule on any Non-
Party objections that were interposed to unsealing their names in that set of documents.
This would require amending the Order and Protocol…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…would either enable or require her to do so.”
Id. Plaintiff never responded. She also has not explained when or how Ms. Maxwell
“acknowledged” her “plans to call Mr. Gow for testimony at trial,” nor why that is relevant to…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…of modification. As the court in EDPM explained:
An examination of Second Circuit case law reveals the following factors are
relevant when determining whether a party has reasonably relied on the protective
order: (1) the scope of the protective order;…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.13
22 pg
…The government has not provided Maxwell with a copy of the subpoena,
but the record shows that the subpoena was incredibly broad and, as explained below, ultimately
unlawful.
The subpoena violated the Fourth Amendment because it was overbroad and because…
giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…frequently was the case, numerous interests could be identified sufficient to rebut the
presumption of access.
The three counsel of record completed this project within the time constraints imposed
by the Court in this expedited proceeding. That is not a…
giuffre-maxwell
gov.uscourts.nysd.447706.1312.0
9 pg
…Id. at 3. As was explained in Plaintiff’s
previous submission filed on January 12, 2022, opposing the first tranche of non-party objections,
the Court is not charged with making a decision on the credibility of deponents or of…
giuffre-maxwell
gov.uscourts.nysd.447706.1105.0
8 pg
…emphasis added). And the Court has explained in no uncertain
terms that parties were justified in their expectation that the Protective Order would not be
modified “for purposes external to the lawsuit in which it was entered.” Id. at 12…
giuffre-maxwell
gov.uscourts.nysd.447706.1071.0
13 pg
…their
entirety. Asked to explain how those materials came into the
firm’s possession, attorneys from Cooper & Kirk explained that
they had obtained access to the materials because Ms. Giuffre
retained them “both to represent her in [Giuffre v. Dershowitz…
giuffre-maxwell
gov.uscourts.nysd.447706.1353.0
6 pg
…13 at 1–2. Nor did Judge McMahon need to
impose obligations on the Government; as she explained: “the fact that the request comes from a
grand jury, whose proceedings are by law conducted in secret, … gives Maxwell[3…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…documents related to Jeffrey Epstein. See
DE 679,
It also
quotes from Doe 1’s prior sworn statements and testimony, which he explained earlier, e.g.,
Given Doe 1’s further explanations, which are no…
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