giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…and 872]; and (b) all unfiled discovery deposition transcripts and exhibits
thereto. The USVI seeks to modify the Protective Order [ECF No. 62] solely to be granted
confidential access to these materials, and, if granted access, agrees to be bound…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.17
12 pg
…Defendant’s arguments change the questions Defendant refused to answer. Accordingly, Ms.
Giuffre’s motion should be granted.
I. PRELIMINARY STATEMENT
Defendant begins her brief with snippets of her self-serving testimony. As the Court is aware,
all of this…
giuffre-maxwell
gov.uscourts.nysd.447706.89.0
10 pg
…Giuffre. For the
reasons set forth below, this Court should deny both of Defendant’s Letter Motions, and grant
Professor Cassell and Mr. Edward’s Motions to Appear Pro Hac Vice.
I. PROCEDURAL HISTORY
Upon Defendant’s April 6, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.1
18 pg
…18, and Motion to Compel Production of certain documents on Defendant’s Third
Amended Privilege Log. For the reasons set forth below, this Court should grant Plaintiff’s
Motion in its entirety.
I. FACTUAL BACKGROUND1
1
On Wednesday, June 8…
giuffre-maxwell
gov.uscourts.nysd.447706.102.0
9 pg
…of non-public, on-going law enforcement investigations. Nor is there any
good reason for the Court to grant a last-minute “stay” of this case (including Defendant’s long-
delayed deposition, which is currently scheduled for Friday). Defendant has…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.7
12 pg
…Defendant’s arguments change the questions Defendant refused to answer. Accordingly, Ms.
Giuffre’s motion should be granted.
I. PRELIMINARY STATEMENT
Defendant begins her brief with snippets of her self-serving testimony. As the Court is aware,
all of this…
giuffre-maxwell
gov.uscourts.nysd.447706.408.0
13 pg
… I am a licensed attorney in the state of Utah. I am authorized to practice before
this Court pursuant to this Court’s Order granting my Application to Appear Pro Hac Vice.
2. I respectfully submit this Declaration in opposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.1
13 pg
… I am a licensed attorney in the state of Utah. I am authorized to practice before
this Court pursuant to this Court’s Order granting my Application to Appear Pro Hac Vice.
2. I respectfully submit this Declaration in opposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.45
13 pg
… I am a licensed attorney in the state of Utah. I am authorized to practice before
this Court pursuant to this Court’s Order granting my Application to Appear Pro Hac Vice.
2. I respectfully submit this Declaration in opposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.18
5 pg
…Espinoza
Farmer
Ward
x Fekkai
x Figueroa
x Fontanilla
x Friedman
x Gibson-Butte
x Gramza
x Gany
x Grant
x Groff
3
Case 1:15-cv-07433-LAP Document 1327-18 Filed 01/05/24 Page 5 of…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…Maxwell’s Objections to Unsealing various of the documents
should be granted.
Plaintiff’s ad hominem attacks -- that the Objections are intended to “stall the unsealing
process,” are “unjustified obstacles” or that the public will never have access to these…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…current victims
(and because they are represented by the same legal counsel as the current victims), the
Government will not be prejudiced if the Court grants the motion. The Court may “at any time”
add new parties to the action…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.8
12 pg
…Accordingly, the Court should grant Ms. Giuffre leave to serve deposition
subpoenas by alternative means.
1
Case 1:15-cv-07433-LAP Document 1320-8 Filed 01/03/24 Page 2 of 12
BACKGROUND
At the heart of this…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…2016 Letter Motion to Compel Defendant to Sit for Her
Deposition (DE 63) - Granted (DE 106).
Plaintiff’s Motion to Compel Documents Subject to Improper Claim of Privilege (DE
33) - Granted in Part (DE 73).
Plaintiff’s Motion…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.24
16 pg
…hereby files this reply
in support of her Motion to Exceed Presumptive Ten Deposition Limit. The motion should be
granted because Ms. Giuffre has shown good cause for needing to exceed the ten deposition limit
and in light of recent…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.17_1
16 pg
…hereby files this reply
in suppo1i of her Motion to Exceed Presumptive Ten Deposition Limit. The motion should be
granted because Ms. Giuffre has shown good cause for needing to exceed the ten deposition limit
and in light of recent…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.27
15 pg
…hereby files this reply
in support of her Motion to Exceed Presumptive Ten Deposition Limit. The motion should be
granted because Ms. Giuffre has shown good cause for needing to exceed the ten deposition limit
and in light of recent…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…with them a presumption of damages suffered.
Accordingly, the court should grant plaintiffs' motion for partial summary judgment on the
issues of the false and defamatory nature of Dershowitz's statements, as well as the issue of the
presumed damages…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.23
9 pg
…Defendant to
Answer Deposition Questions (DE 143). On June 20, 2016, this Court granted Ms. Giuffre’s Motion
and directed Defendant to sit again for her deposition (June 20, 2016 Sealed Order, filed in redacted
form at DE 264-1…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.18_2
15 pg
…hereby files this reply
in suppo1i of her Motion to Exceed Presumptive Ten Deposition Limit. The motion should be
granted because Ms. Giuffre has shown good cause for needing to exceed the ten deposition limit
and in light of recent…