giuffre-maxwell
gov.uscourts.nysd.447706.172.0
28 pg
… Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S REDACTED MOTION TO EXCEED PRESUMPTIVE TEN
DEPOSITION LIMIT IN FEDERAL RULE CIVIL PROCEDURE 30(A)(2)(a)(ii)
Sigrid McCawley (Pro Hac…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…Ms. Giuffre’s lawyers and a former federal judge—are little
more than an effort to revive and further the false and scurrilous allegations of sexual misconduct
that compelled me to seek the Court’s assistance in the first place…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
…Ms. Giuffre’s lawyers and a former federal judge—are little
more than an effort to revive and further the false and scurrilous allegations of sexual misconduct
that compelled me to seek the Court’s assistance in the first place…
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
gov.uscourts.nysd.447706.5.0
2 pg
…Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on…
giuffre-maxwell
gov.uscourts.nysd.447706.3.0
2 pg
…Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.16
22 pg
…and upon information and belief as to all other
matters, as follows:
1. This cause of action arises under federal statutes and jurisdiction is
proper under 28 U.S.C. $ 1331.
2. Plaintiff files this Complaint under a pseudonym…
giuffre-maxwell
gov.uscourts.nysd.447706.542.8
4 pg
…as exempt
organizations under section 501( c)( 3) of the Internal Revenue Code, or the corresponding section of any future federal tax
code. The corporation is organized to provide assistance to victims of sexual abuse as well as victims of…
giuffre-maxwell
gov.uscourts.nysd.447706.86.0
3 pg
…GIUFFRE, in the above-captioned action.
I am in good standing of the bar(s) of the state(s) of Florida and there are no pending
disciplinary proceedings against me in any state or federal court.
Dated: April 7, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.8.0
2 pg
…Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on…
giuffre-maxwell
gov.uscourts.nysd.447706.435.0
27 pg
…Ms. Giuffre’s lawyers and a former federal judge—are little
more than an effort to revive and further the false and scurrilous allegations of sexual misconduct
that compelled me to seek the Court’s assistance in the first place…
giuffre-maxwell
gov.uscourts.nysd.447706.4.0
2 pg
…in the above-captioned action.
I am in good standing of the bar(s) of the state(s) of
Florida
_ _ _ _ _ _ _ _ _ _ _ __ _ _ _ and there are no pendi ng disciplinary proceedings against
me in any state or federal court.
Dated: September 2 1…
giuffre-maxwell
gov.uscourts.nysd.447706.363.5
6 pg
…Case No. 08-80736-CIV-
MARRA/JOHNSON, [ECF No. 291-1] (the “Federal Action”).
2. All photographs and video in the original, native format in which they were taken (not a
paper copy) of you with Alan M. Dershowitz.
3…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.14
6 pg
…26 times. After Epstein's arrest in July 2006,
federal tax records show Epstein donated $25,000 to the Clinton Foundation that year.
Epstein was also a regular visitor to Donald Trump's Mar-a-Lago, and the two were…
giuffre-maxwell
1320-30
27 pg
…Case 1:15-cv-07433-LAP Court Reporting
Document & Video,
1320-30 Filed Inc. Page 5 of 27
01/03/24
1 Pursuant to Notice and the Federal Rules
2 of Civil Procedure, the VIDEOTAPED …
giuffre-maxwell
gov.uscourts.nysd.447706.2.0
2 pg
…1s1 ( ] 430 BAN KS & BANKING
INS TRUMENT SLANDE:R ( J 368 ASBESTOS PERSONAL I J S 0 OTHER I I 450 COMMERCE
I J 150 RE COVERY OF [ J 330 FEDERAL INJURY PRODUCT …
giuffre-maxwell
gov.uscourts.nysd.447706.1320.30
27 pg
…Case 1:15-cv-07433-LAP Court Reporting
Document & Video,
1320-30 Filed Inc. Page 5 of 27
01/03/24
1 Pursuant to Notice and the Federal Rules
2 of Civil Procedure, the VIDEOTAPED …
giuffre-maxwell
gov.uscourts.nysd.447706.216.8
4 pg
…Prince Andrew, and Clinton, and reveals that she has instructed her
lawyers — who include former federal judge, Paul Cassell, and victims’ rights expert Bradley Edwards — to bring the men
to justice.
“I have directed my attorneys … to pursue all…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…the needs of the case.
Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such discovery
is prohibited by the Federal Rules of Civil Procedure, particularly under the 2015 amendments to
Rule 26(b)(1), Fed…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…the needs of the case.
Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such discovery
is prohibited by the Federal Rules of Civil Procedure, particularly under the 2015 amendments to
Rule 26(b)(1), Fed…