giuffre-maxwell
gov.uscourts.nysd.447706.1330.8
10 pg
…she had no
memory of any of the events. As a result, Ms. Giuffre was forced to file a Motion to Compel
Defendant to Answer Deposition Questions Filed under Seal (DE 143). On June 20, 2016, this
Court granted Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…For example, Jane Doe 3 alleged that she had been forced by Epstein to have sexual
relations with various persons, including Alan Dershowitz – who had been one of Epstein’s
defense attorneys negotiating the non-prosecution deal and arranging to…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…Giuffre would be forced to apply to the Court to lift the confidentiality designations
from parallel discovery materials in this case that refute what Defendant and her proxies say in
the media (materials that are present in abundance in this…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.0
18 pg
…argue that they should be fellow
travelers in this pursuit, lest they “be forced to file a separate suit raising their claims” resulting
in “duplicative litigation” (DE 280 at 11). The Court finds that justice does not require adding
new…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
… Ms. Maxwell was forced
to show the Court all the questions she had answered beyond those authorized by the Court’s
order and the number of repetitive and harassing questions. This submission of the July 2016
transcript to the Court…
giuffre-maxwell
gov.uscourts.nysd.447706.185.4
10 pg
…argue that they should be fellow
travelers in this pursuit, lest they “be forced to file a separate suit raising their claims” resulting
in “duplicative litigation” (DE 280 at 11). The Court finds that justice does not require adding
new…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.14_2
40 pg
…they had suffered sexual abuse from
Epstein. For example, Jane Doe 3 alleged that she had been forced by Epstein to have sexual
relations with various persons
- Mccawley Deel., Exhibit 2 at 4. Jane Doe 3 also alleged that Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.1113.0
7 pg
…should therefore be
proportionally narrow. While Mr. Dershowitz will not be forced to
“litigate this action with one arm tied behind his back,” (dkt.
no. 144 at 6 n.4), that does not require that the Court allow Mr.
Dershowitz…
giuffre-maxwell
gov.uscourts.nysd.447706.139.0
7 pg
…to keep these materials confidential. The ability of the law
enforcement agency to conduct its investigation unimpeded will be impaired if Ms. Giuffre is
forced to disclose the information. Accord In re The City of New York, 607 F3d 923…
giuffre-maxwell
1320-18
40 pg
…For example, Jane Doe 3 alleged that she had been forced by Epstein to have sexual
relations with various persons, including Alan Dershowitz – who had been one of Epstein’s
defense attorneys negotiating the non-prosecution deal and arranging to…
giuffre-maxwell
gov.uscourts.nysd.447706.542.5
11 pg
…4 argue that they should be fellow
travelers in this pursuit, lest they " be forced to file a separate suit raising their claims" resulting
in " duplicative litigation" ( DE 280 at 11). The Court finds that justice does not require adding
…
giuffre-maxwell
gov.uscourts.nysd.447706.49.0
12 pg
…Thus, Ms. Maxwell
was forced to file her request for a protective order with the Court.
Ms. Maxwell has a real need for a protective order in this case. Plaintiff and her counsel
have made numerous statements to the media…
giuffre-maxwell
gov.uscourts.nysd.447706.363.4
11 pg
…argue that they should be fellow
travelers in this pursuit, lest they “be forced to file a separate suit raising their claims” resulting
in “duplicative litigation” (DE 280 at 11). The Court finds that justice does not require adding
new…
giuffre-maxwell
gov.uscourts.nysd.447706.965.0
9 pg
…do not want to be forced to look but perhaps I will
18 have to.
19 My best recollection is that the summary judgment
20 briefing included reference to papers other than just the
21 summary judgment papers but also…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.5
11 pg
…argue that they should be fellow
travelers in this pursuit, lest they “be forced to file a separate suit raising their claims” resulting
in “duplicative litigation” (DE 280 at 11). The Court finds that justice does not require adding
new…
giuffre-maxwell
gov.uscourts.nysd.447706.1060.0
2 pg
…Instead, Maxwell apparently seeks to force Dershowitz and this
Court to litigate piecemeal each and every individual subpoena for materials from each and every
witness in the Maxwell case from whom testimony and documents is sought. Maxwell seeks to
force…
giuffre-maxwell
gov.uscourts.nysd.447706.1062.0
7 pg
…960 (S.D.N.Y. 1987) (explaining, in denying
request for discovery, that while “the protective order has been in force . . . numbers of non-
parties have been deposed or provided documents on assurance of the confidentiality of their
Case…
giuffre-maxwell
gov.uscourts.nysd.447706.1067.0
10 pg
…plain terms of the Protective Order do not support Maxwell’s reliance
argument. The Protective Order at issue specifically provided that it would “have no force and
effect on the use of any CONFIDENTIAL INFORMATION at trial.” Dkt. 39-1…
giuffre-maxwell
gov.uscourts.nysd.447706.41.5
18 pg
…stops: 1",
14. 165. This Protective Order shall have no force and effect on the use of any List tab + 6.25", Right + Not at 0.5"
Formatted: Font: 12 pt
CONFIDENTIAL INFORMATION at trial in this matter. …
giuffre-maxwell
gov.uscourts.nysd.447706.1206.4
23 pg
…stops: 1",
14. 165. This Protective Order shall have no force and effect on the use of any List tab + 6.25", Right + Not at 0.5"
Formatted: Font: 12 pt
CONFIDENTIAL INFORMATION at trial in this matter. …