giuffre-maxwell
gov.uscourts.nysd.447706.1078.1
8 pg
…United States Constitution guarantees an accused the
right to an impartial jury. This fundamental guarantee is part of a criminal defendant’s basic right
to a fair trial, which requires that a defendant must be judged by a jury of…
giuffre-maxwell
gov.uscourts.nysd.447706.57.3
39 pg
…an implied duty under the regulations to investigate, there
was no duty to report; more fundamentally, it had not been established that Total
was the operator of the site for the purpose of the COMAH Regulations. That
E would be…
giuffre-maxwell
gov.uscourts.nysd.447706.561.0
22 pg
…TO PRECLUDE INTRODUCTION
OF TESTIMONY FROM A WITNESS MS. GIUFFRE HAS NOT HAD THE
OPPORTUNITY TO CROSS EXAMINE. ............................................................................8
A. Allowing Excerpts from the Dershowitz Deposition in the Florida Case Would
be Fundam…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…grammar, or typographical errors.
7
could appeal to the Oprah/female set as well as the Wall Streeters
who follow Epstein — a hedge fund king.
Here are a few of our stories about Virginia, plus some examples
of the…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.36
10 pg
…. . has to say about all this.” Motion to Present Epstein
Testimony at 14. There is no indication in Cerro Gordo Charity v. Fireman's Fund Am. Life Ins.
Co., 819 F.2d 1471 (8th Cir. 1987), on which plaintiff relies…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.31
10 pg
…who was forced into sexual slavery by Dershowitz's
close friend and client, billionaire hedge fund financier and convicted pedophile
Jeffrey Epstein
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…created and directed the companies whose aircraft
transported the young women and girls, owned and maintained the
secluded islands to which they were transported, and provided
sources of funding for this activity.” (USVI Reply Br. at 3
(citing CICO Compl. …
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…Jeffery when he went to trail, made huge endorsements to the Clinton Foundation
to help fund her 2008 presidential campaign.
I personally met Alan numerous times as Jeffery had sent him to my legal aid, to deal with a case…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.18
50 pg
…Spin Master Ltd. v. Bureau Veritas Consumer Products Service, Inc.,
2016 WL 690819 (W.D.N.Y., 2016) ....................................................................................... 30
T. Rowe Price Small-Cap Fund, Inc. v. Oppenheimer & Co., Inc.,
174 F.R.D. 38 (S.D.N.Y. 1997)…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.6
32 pg
…Document 1328-6 Filed 01/05/24 Page 14 of 32
could appeal to the Oprah/female set as well as the Wall Streeters
who follow Epstein — a hedge fund king.
Here are a few of our stories about Virginia…
giuffre-maxwell
gov.uscourts.nysd.447706.102.0
9 pg
…Inc., 676
F.3d 83, 98 (2d Cir. 2012), quoting Trs. of Plumbers & Pipefitters Nat'l Pension Fund v.
Transworld Mech., Inc., 886 F.Supp. 1134, 1139 (S.D.N.Y.1995).
II. ARGUMENT
Defendant first notes that she contacted…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…relevant. Ms. Giuffre respectfully requests that this Court
direct Maxwell to produce all responsive documents for the time period from 1999 to the
present.6
Defendant Maxwell has also asserted fundamentally improper general objections which
should be overruled. Am. Rock…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…behavior that I
abhor and have never ever been party to, witness to events that I have never seen,
living off trust funds that I have never ever had, party to stories that have changed
materially both in time place…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…It would be fundamentally unfair to
allow Giuffre to continue to press these allegations where she and her attorneys have had the full
benefit of discovery already conducted concerning these allegations which is in her possession and
which is being…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…insure their irrelevance.”
United States v. Amodeo, 71 F.3d 1044, 1049 (2d Cir. 1995) (“Amodeo II”); United States v. All
Funds on Deposit at Wells Fargo Bank, 643 F. Supp. 2d 577, 583 (S.D.N.Y. 2009). “Especially
…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…mind’; and
(3) that the missing evidence is ‘relevant’ to the party's claim or defense such that a reasonable
trier of fact could find that it would support that claim or defense.” Id. (citing Residential
Funding Corp. v. DeGeorge…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…York law, it is well-settled that truth is an absolute, unqualified defense to a civil defamation
action. It is an equally fundamental concept that substantial truth suffices to defeat a charge of
libel.” Jewell v. NYP Holdings, Inc., 23…
giuffre-maxwell
gov.uscourts.nysd.447706.1196.0
32 pg
… The Court observes, however, that
3 "the right of an accused to fundamental fairness in the jury
4 selection process" may be a countervailing interest that weighs
5 against public access to documents.
6 Here, however, the Court rejects Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1105.0
8 pg
…this point, there can be little dispute: Mr. Dershowitz has effectively distilled his
request down to a narrower set of documents that target – with pinpoint accuracy – fundamental
non-party privacy interests. See DE 153 (Dershowitz) at 3 (requesting, among other…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…Civ. P. 37(e)(2). The new Rule
37 “rejects cases such as Residential Funding Corp. v. DeGeorge Financial Corp., 306 F.3d 99
8
Case 1:15-cv-07433-LAP Document 1330-16 Filed 01/05/24 Page…