giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
…has expressed fear for her life in deciding to present herself
and her testimony publicly against Jeffrey Epstein and the Defendant. She contends she
has already been followed from her home by two male persons. This conclusion is not
unreasonable…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.21
11 pg
…Bloody Sunday not to give interviews so I am cautious and this is the time to speak.
I can say no more. I hope our advice is followed .
Philip
Sent from my iPhone
On 9 Jan 2015, at 21:53…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.10
15 pg
…12 years ago,
10 received a lot of professional adv ice and gone
11 through an awful lot based upon what ha ppened
12 12 years ago.
13 She has been advised and has followed the
14 advice to forget…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.22
22 pg
…by silence.
Your are not guilty and must follow Dershowtiz line. He is a leading lawyer and he hasn't followed the don't say
anything for fear of litigation. He has rightly called YR bluff and shouted his innocence.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.43
4 pg
…a whole.
PHILIP WILLIAMS: It all seems a world away from the golden glow of recent Royal
events - a wedding that cemented the popularity of Prince William and his bride.
Followed of course by the arrival of baby Prince George…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.31
10 pg
…I was too attached
8 to the case, basically, and I was creating
9 probable cause rather than developing probable
10 cause.
11 Aside from being followed by private
12 investigators myself, having my own trash
13 pulled, you know…
giuffre-maxwell
gov.uscourts.nysd.447706.515.0
12 pg
…assertions contained in .1 (Of
1
Plaintiff now takes the stance that
1
course, Plaintiff’s Joinder Motion was followed three days later by the denial of Ms. Maxwell’s
press agent that forms the basis of t…
giuffre-maxwell
gov.uscourts.nysd.447706.590.1
4 pg
…a whole.
PHILIP WILLIAMS: It all seems a world away from the golden glow of recent Royal
events - a wedding that cemented the popularity of Prince William and his bride.
Followed of course by the arrival of baby Prince George…
giuffre-maxwell
gov.uscourts.nysd.447706.408.0
13 pg
…2
. Further efforts from the Government to avoid
producing any discovery followed (see generally DE 225-1 at 4-5),2 ultimately leading to a
further Court ruling in June 2013 that the Government should produce documents. DE 189…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.5
12 pg
…in that manner, Plaintiff should not be permitted to
1
course, Plaintiff’s Joinder Motion was followed three days later by the denial of Ms. Maxwell’s
press agent that forms the basis of this defamation action.). While the present…
giuffre-maxwell
gov.uscourts.nysd.447706.58.0
2 pg
…Counsel for Plaintiff conferred with Defendant’s
Counsel by sending a detailed letter detailing the request, and counsel for both parties have
followed up by placing two phone calls, but have been unable to speak directly due to conflicting
schedules…
giuffre-maxwell
gov.uscourts.nysd.447706.1231.0
3 pg
… 3(e). Intervenors seek confirmation that this procedure will be followed, so that
redacted versions of the Does’ objections are placed on the public docket.
Atlanta | Austin | Boston | Charlotte | Chicago | Dallas | Denver | Fort…
giuffre-maxwell
gov.uscourts.nysd.447706.88.0
7 pg
…2016, indicated that it would treat the letter objection as a Motion and scheduled a
hearing on the objection. Mr. Edwards’ Motion to Appear followed.
Mr. Edwards’ appearance in this matter is as inappropriate as that of Mr. Cassell.
Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.11
9 pg
…2017, followed up on this by presenting argument on the Motion to Compel
that relied almost entirely on the rules-violating reply.
Because of the unfairness from plaintiff’s chaotic approach to motion practice, we
requested on March 9 leave…
giuffre-maxwell
gov.uscourts.nysd.447706.972.0
1 pg
…the mandate issues.
Though Ms. Maxwell is considering filing a petition for rehearing, we believe it highly
unlikely such petition would be successful as the Second Circuit panel directly followed
governing precedent. Ms. Maxwell otherwise appears to agree that the…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…999 (11th Cir. 2014). Congress
has also followed the developments in the case closely, recently amending the CVRA to insure
that in the future crime victims receive notice of any non-prosecution agreement entered into by
the Government. See Pub…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…thought she appeared to “about 25” years old. It turned
out that my estimate was correct. This exchange followed:
[DERSHOWITZ]: … I must say that during the recess, my wife
Googled Tatiana and found out that she was, in fact…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…personal financial information, claimed to be
related only to issue of punitive damages, as premature before dispositive motions).
In circumstances such as these, the procedure followed in a similarly contentious case by
this Court, Guccione v. Flynt, may be the…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…after he
started the investigation into the crimes that took place at the Palm Beach mansion, he was
followed by strange men and “investigated”. He also has made public statements that he sent to
victims regarding the failure of the…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.2
26 pg
… Sure. And when you got the case six
22 months later, if there hadn't been follow-up, you
23 would have followed up on it, right?
24 MS. SCHULTZ: Object to form.
25 THE WITNESS: Correct.
Case 1:15…
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