giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…Eleven
months into this case, and after the close of fact discovery, Defendant continues to refuse to
abide by her most basic and fundamental discovery obligations. A summary of this ongoing and
willful non-compliance, as well as a supplement…
giuffre-maxwell
gov.uscourts.nysd.447706.203.0
15 pg
… Case 1:15-cv-07433-RWS Document 203 Filed 06/13/16 Page 2 of 15
TABLE OF CONTENTS
Page
I. THE PROPOSED DEPOSITIONS ARE IMPORTANT TO THE FUNDAMENTAL
CLAIMS AND DEFENS…
giuffre-maxwell
gov.uscourts.nysd.447706.211.0
16 pg
… Case 1:15-cv-07433-LAP Document 211 Filed 06/14/16 Page 3 of 16
TABLE OF CONTENTS
Page
I. THE PROPOSED DEPOSITIONS ARE IMPORTANT TO THE FUNDAMENTAL
CLAIMS AND DEFE…
giuffre-maxwell
gov.uscourts.nysd.447706.689.0
42 pg
…8
Brink’s Inc. v. City of New York,
717 F.2d 700 (2d Cir. 1983)........................................................................................................ 8
Cerro Gordo Charity v. Fireman’s Fund Am. Life Ins. Co.,
819 F.2d 1471 (8th Cir. 1987) .........................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.8
16 pg
…Case 1:15-cv-07433-LAP Document 1256-8 Filed 05/03/22 Page 3 of 16
TABLE OF CONTENTS
Page
I. THE PROPOSED DEPOSITIONS ARE IMPORTANT TO THE FUNDAMENTAL
CLAIMS AND DEFENSES I…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.11
15 pg
…Case 1:15-cv-07433-LAP Document 1256-11 Filed 05/03/22 Page 3 of 15
TABLE OF CONTENTS
Page
I. THE PROPOSED DEPOSITIONS ARE IMPORTANT TO THE FUNDAMENTAL
CLAIMS AND DEFEN…
giuffre-maxwell
gov.uscourts.nysd.447706.1042.0
2 pg
…that which has already been sealed for far too long. She further fundamentally
mischaracterizes the role of the media in seeking access to court records: The media are not
distinguishable from the public; they are the surrogates for the public…
giuffre-maxwell
gov.uscourts.nysd.447706.356.0
17 pg
…sister patronage of her art work; he’d promised the
younger funding for a trip abroad that would give her the work experience she needed on
her resume for a place at an Ivy League university, which she desperately wanted …
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
… Annoyance, embarrassment, oppression, undue burden (“Privacy Interests”) (“CI-
3”).
4. Preserving the fundamental rights of suspects or others under criminal
investigation (“CI-4”).
5. Improper submission of documents thereby weaponizing judicial documents (“CI-
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.16
10 pg
…16 Filed 01/05/24 Page 3 of 10
Plaintiff’s misplaced argument that Ms. Maxwell is somehow required to make Dr.
Esplin available at trial violates the fundamental rules of trial and the requirements for rebuttal
witnesses. Of course…
giuffre-maxwell
gov.uscourts.nysd.447706.1123.0
2 pg
…the objection
(and non-objection) was lodged prior to receipt of the excerpts. Moreover, it is fundamentally
inconsistent to permit “unsealing” but keeping their names anonymous. Ms. Maxwell raised
some concerns about Doe 1 in the unredacted “Reply in Support…
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.447706.315.0
17 pg
…sister patronage of her art work; he’d promised the
younger funding for a trip abroad that would give her the work experience she needed on
her resume for a place at an Ivy League university, which she desperately wanted …
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.447706.1161.0_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.447706.378.0
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)…
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