giuffre-maxwell
gov.uscourts.nysd.447706.1090.10_2
4 pg
…07433-RWS
v.
Ghislaine Maxwell,
Defendant.
______________________________/
NON-REDACTED DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF
PLAINTIFF’S MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT IN
FEDERAL RULE OF CIVIL PROCEDURE 30(A)(2)(a)(ii), FILED UNDER SEAL
I…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…by and
through undersigned counsel, to file this motion pursuant to Federal Rule of Civil Procedure 21
to join this action, on the condition that they not re-litigate any issues already litigated by Jane
Doe #1 and Jane Doe…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.6
10 pg
…
IT APPEARING that the Unitl,d States Attorney's Office and the Federal Bureau of
Investigation have concluded their own investigation into Epstein's background and any
offtme1 that may have been committed by Epstein against the United States from…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…by and
through undersigned counsel, to file this motion pursuant to Federal Rule of Civil Procedure 21
to join this action, on the condition that they not re-litigate any issues already litigated by Jane
Doe #1 and Jane Doe…
giuffre-maxwell
1320-9
10 pg
…by and
through undersigned counsel, to file this motion pursuant to Federal Rule of Civil Procedure 21
to join this action, on the condition that they not re-litigate any issues already litigated by Jane
Doe #1 and Jane Doe…
giuffre-maxwell
gov.uscourts.nysd.447706.526.0
5 pg
…ANY
EVIDENTIARY FOUNDATION, HEARSAY, AND NOT RELEVANT. ........................... 3
II. THE TESTIMONY IS INADMISSIBLE UNDER RULE 702 OF THE FEDERAL RULES
OF EVIDENCE ....................................................................................................................... 4
A. Handwriting Analysis Lacks…
giuffre-maxwell
gov.uscourts.nysd.447706.592.0
5 pg
…DEFENDANT’S COUNTER-DESIGNATIONS TO PLAINTIFF’S
DEPOSITION DESIGNATIONS
Defendant Ghislaine Maxwell, through her attorneys and pursuant to Rule 32 of the
Federal Rules of Civil Procedures, hereby submits her counter-designations in accordance with
the Court’s October 3…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.3
10 pg
…by and
through undersigned counsel, to file this motion pursuant to Federal Rule of Civil Procedure 21
to join this action, on the condition that they not re-litigate any issues already litigated by Jane
Doe #1 and Jane Doe…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…Argument................................5
Ms. Giuffre’s Deposition in the Defamation Case...........................................................................7
The Settlement of the Defamation Case..........................................................................................7
LEGAL STANDARDS FOR W…
giuffre-maxwell
gov.uscourts.nysd.447706.1353.0
6 pg
…RWS)
(S.D.N.Y.), for the limited and exclusive purpose of complying with
grand jury process to provide materials to the Government in con-
nection with a federal grand jury investigation:
IT IS HEREBY ORDERED, that Boies Schiller & Flexner…
giuffre-maxwell
gov.uscourts.nysd.447706.1194.0_6
2 pg
…comfort in the fact that Ms. Maxwell
recognizes that she has the Federal Rules of Criminal Procedure and evidence at her disposal when
the appropriate time comes to fight this fight down the road.”). The Court’s reasoning was clear…
giuffre-maxwell
gov.uscourts.nysd.447706.185.4
10 pg
…unnamed victims, Jane Doe 3 and Jane Doe 4, moved
to join as petitioners in this action pursuant to Federal Rule of Civil Procedure 21. (DE 280).
Petitioners (Jane Doe 1 and Jane Doe 2) support the Rule 21 Motion. …
giuffre-maxwell
gov.uscourts.nysd.447706.562.1
13 pg
…with the assistance of numerous
co-conspirators, Epstein abused more than thirty (30) minor underage girls, a fact confirmed by
state and federal law enforcement.
10. As part of their sex trafficking efforts, Epstein and Maxwell intimidated Giuffre
into remaining…
giuffre-maxwell
gov.uscourts.nysd.447706.1339.0
3 pg
… Case 1:15-cv-07433-LAP Document 1339 Filed 01/12/24 Page 2 of 3
to other categories of sensitive information set out in the Court’s
individual practices and Federal Rule of Civil Procedure 5.2.
Second…
giuffre-maxwell
gov.uscourts.nysd.447706.1262.1
2 pg
…Code (Title 28, U.S.C.) which pertain to the
jurisdiction of, and practice in, the United States District Courts;
b. The Federal Rules of Civil Procedure;
c. The Federal Rules of Criminal Proce…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.14_2
40 pg
…Giuffre’s Deposition in the Defamation Case........................................................................... 7
The Settlement of the Defamation Case .......................................................................................... 7
LEGAL STANDARDS FOR WAIVER............................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.962.0
7 pg
…Resp. 3 (emphasis
supplied). It is extraordinary because it is a false statement made to a federal court.
None of the three unseal motions concerns the materials at issue in Ms. Maxwell’s show-
cause motion. That motion seeks relief…
giuffre-maxwell
1320-18
40 pg
…Argument................................5
Ms. Giuffre’s Deposition in the Defamation Case...........................................................................7
The Settlement of the Defamation Case..........................................................................................7
LEGAL STANDARDS FOR W…
giuffre-maxwell
gov.uscourts.nysd.447706.1.0
12 pg
…with the assistance of numerous
co-conspirators, Epstein abused more than thirty (30) minor underage girls, a fact confirmed by
state and federal law enforcement.
10. As part of their sex trafficking efforts, Epstein and Maxwell intimidated Giuffre
into remaining…
giuffre-maxwell
gov.uscourts.nysd.447706.24.1
13 pg
…with the assistance of numerous
co-conspirators, Epstein abused more than thirty (30) minor underage girls, a fact confirmed by
state and federal law enforcement.
10. As part of their sex trafficking efforts, Epstein and Maxwell intimidated Giuffre
into remaining…