giuffre-maxwell
gov.uscourts.nysd.447706.1285.0
6 pg
…2022,
our firm was retained to represent Doe 171 in this matter, and we now write to
respectfully request two different forms of relief on an expedited basis, in light of
their gravity and potential effect on a pending appeal…
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.447706.1286.0
6 pg
…2022,
our firm was retained to represent Doe 171 in this matter, and we now write to
respectfully request two different forms of relief on an expedited basis, in light of
their gravity and potential effect on a pending appeal…
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.447706.1204.0
3 pg
…Preska:
I write in reply to the letters filed by plaintiff and the Miami Herald in opposition to
Ms. Maxwell’s limited motion for reconsideration. As explained below, neither letter
appreciates the stakes, and both misunderstand the basis for Ms…
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.447706.1008.0
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.447706.1329.0
3 pg
…the alphabetical order of
1 With respect to the remaining Does, the Court has explained its
reasons for declining to unseal their names, and any party
dissatisfied with those reasons can appeal to the Court of Appeals.
2
the list…
giuffre-maxwell
gov.uscourts.nysd.447706.1128.0_4
1 pg
…172 199, and 230 (ECF No. 1068-1) later today.
By order dated October 19, 2020, after expedited briefing and a hearing held on October
13, 2020, the Second Circuit affirmed this Court’s order (ECF No. 1126), rejecting Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1227.0
2 pg
…Tr. of July 1, 2021 Ruling at 7:9–14. As the Court
explained during its most recent ruling, if there is identifying information about Doe himself that
he contends must be redacted, he may request that relief under seal…
giuffre-maxwell
gov.uscourts.nysd.447706.1095.0
2 pg
…file the exhibit under
seal is GRANTED pending review of the matter and without prejudice to reconsideration nostra
sponte. It is further ORDERED that the appeal is expedited. Appellant’s principal brief must be
filed on or before August 20…
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.447706.1135.0_6
1 pg
…regarding her proposed redactions during a
telephone conference at 1 p.m. today. While undersigned counsel explained the bases for her
disagreement and pointed out other areas that should be redacted, Ms. McCawley simply
stated that she disagreed without explanation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.599.0
12 pg
…Ms. Giuffre has correctly explained why Taylor should not be
allowed to opine on
The remaining opinions offered by Taylor would not be relevant or helpful to the jury,
which is why Taylor should be precluded from testifying at all…
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.447706.1219.43
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.447706.223.2
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.447706.113.0
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.447706.1130.0_3
1 pg
…172 199, and 230 (ECF No. 1068-1) later today.
By order dated October 19, 2020, after expedited briefing and a hearing held on October
13, 2020, the Second Circuit affirmed this Court’s order (ECF No. 1126), rejecting Maxwell…
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