giuffre-maxwell
gov.uscourts.nysd.447706.1218.9
18 pg
… In May 2009, Ms. Roberts filed a civil suit against Mr. Epstein, in which she
alleged that Mr. Epstein required that she “be sexually exploited by Defendant’s adult male
peers, including royalty, politicians, academicians, businessmen, and/or other professional…
giuffre-maxwell
gov.uscourts.nysd.447706.1287.0
2 pg
…request therein, is
resolved by the Court.
Document
# of Page Line(s) Identifier Redaction Requested
Transcript
1283 5 24-25 All text, as explained in Motion No text, as explained in Motion
1283 6 …
giuffre-maxwell
gov.uscourts.nysd.447706.1033.0
1 pg
…unsealed. Plaintiff’s list is identical to Defendant’s list, except that Defendant has failed to include
two decided motions: Dkts. 468 & 567. As Plaintiff explained in her February 5, 2020 letter, Dkt.
1029, Judge Sweet decided both motions, and…
giuffre-maxwell
gov.uscourts.nysd.447706.1008.0
5 pg
…1995). As the Second Circuit explained on appeal in this matter, a document is relevant
to the performance of the judicial function “if it would reasonably have the tendency to influence
Case 1:15-cv-07433-LAP Document 1008…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…2016. Plaintiff’s counsel still has not explained why they waited more than two
months to disclose the witness, nor why they represented to the Court that she was a “recent” discovery.
1
BACKGROUND
Plaintiff first identified Sarah Ransome…
giuffre-maxwell
gov.uscourts.nysd.447706.223.2
7 pg
…are
authorized to accept service of a subpoena for Jeffrey
Epstein's testimony in the Maxwell action.
You explained that it would be Epstein's position that he would
be invoking his Fifth Amendment privilege as to all questions
relating…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.30
19 pg
…2016. Plaintiff’s counsel still has not explained why they waited more than two
months to disclose the witness, nor why they represented to the Court that she was a “recent” discovery.
1
Case 1:15-cv-07433-LAP…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…The EarthLink account
The second account, is, as Ms. Maxwell has repeatedly explained
to Plaintiff’s counsel, an account that she does not recognize, that she does not recall having ever
logged onto, and for which she has no password…
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.447706.1295.8
9 pg
…discovery is a valuable right and should not
be unnecessarily restricted, the ‘necessary’ restriction may be broader when a non-party is the
target of discovery.”).
As explained above, this non-party was asked a host of questions that ran…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…The second account, , is, as Ms. Maxwell has repeatedly explained
to Plaintiff’s counsel, an account that she does not recognize, that she does not recall having ever
logged onto, and for which she has no password. See DE 320…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…s needs for
discovery, the Court should enter a protective order against further discovery (DE 640) and deny
Defendant’s Combined Motion to Compel1 (DE 655).
As explained in Non-Party Ransome’s Motion for Protective Order, Defendant should not
…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.9
29 pg
…s needs for
discovery, the Court should enter a protective order against further discovery (DE 640) and deny
Defendant’s Combined Motion to Compel1 (DE 655).
As explained in Non-Party Ransome’s Motion for Protective Order, Defendant should not
…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.12
11 pg
…original search resulted
in approximately 9,000 documents and communications containing one or more term in the
content or meta-data. The volume of the documents is explained by the breadth of the terms
searched, resulting in pulling non-relevant…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…try to have his client , Jeffrey Epstein
available to be interviewed. I explained I would be interested in
conducting an interview with his client as well as other employees
that are employed within the house. Atty. Fronstin advised he would
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
…try to have his client , Jeffrey Epstein
available to be interviewed. I explained I would be interested in
conducting an interview with his client as well as other employees
that are employed within the house. Atty. Fronstin advised he would
…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.2
70 pg
…your flight logs and journal. I told him you must remain a
confidential source and the way he explained it was that all of the info you pass through me will not be used in court, only as a lead…
giuffre-maxwell
1320-13
45 pg
…try to have his client , Jeffrey Epstein
available to be interviewed. I explained I would be interested in
conducting an interview with his client as well as other employees
that are employed within the house. Atty. Fronstin advised he would
…
giuffre-maxwell
gov.uscourts.nysd.447706.320.0
11 pg
…original search resulted
in approximately 9,000 documents and communications containing one or more term in the
content or meta-data. The volume of the documents is explained by the breadth of the terms
searched, resulting in pulling non-relevant…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…to sit for a deposition that will presumably cover the same privileged topics. As
the New York Court of Appeals explained in its most recent decision on the Shield Law, where
“the entire focus” of a reporter’s testimony would…
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