giuffre-maxwell
gov.uscourts.nysd.447706.1167.2
27 pg
…These arguments
were made, and documents filed, for purposes of distraction and harassment, and have nothing to
do with the issues presented by the motion. This is classic abuse of the courts records and files.
The Response and Exhibits were…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.1_2
28 pg
…These arguments
were made, and documents filed, for purposes of distraction and harassment, and have nothing to
do with the issues presented by the motion. This is classic abuse of the courts records and files.
The Response and Exhibits were…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…prostitute I have been the
target of outright lies, innuendo, slander, defamation and salacious gossip and
harassment; headlines made up of quotes I have never given, statements I have
never made, trips with people to places I have never been…
giuffre-maxwell
gov.uscourts.nysd.447706.1237.0
20 pg
…Judge Nathan squarely
rejected the defense’s argument that “anonymity is necessary to protect its witnesses from scrutiny
and harassment because of the significant publicity this case has garnered” because “these
generalized concerns are present in every high-profile criminal…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
… see also
DE 339 at 13-24 (detailing the record support for the argument that defense “counsel instructed
Maxwell not to answer to enforce the Court’s Order and to prevent harassment by plaintiff’s
3
Case 1:15…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…Request in
that it represents a complete invasion of privacy. A non-party should not be subjected to undue
harassment serving no admissible purpose.
9
Without waiving such objections, a copy of non-party Sarah Ransome’s current passport…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…of privacy. A non-party should not be subjected to undue
harassment serving no admissible purpose.
9
Case 1:15-cv-07433-LAP Document 1332-8 Filed 01/08/24 Page 11 of 27
Without waiving such objections, a…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.0
56 pg
…These arguments
were made, and documents filed, for purposes of distraction and harassment, and have nothing to
do with the issues presented by the motion. This is classic abuse of the courts records and files.
The Response and Exhibits were…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…380 F.3d 110 (2d Cir. 2004) (per curiam)
(witnesses and third parties "possess strong privacy interests,
because being identified as part of a law enforcement
investigation could subject them to 'embarrassme nts and
harassment'" ), "with the deviant and the…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…Request in
that it represents a complete invasion of privacy. A non-party should not be subjected to undue
harassment serving no admissible purpose.
9
Without waiving such objections, a copy of non-party Sarah Ransome’s current passport…
giuffre-maxwell
gov.uscourts.nysd.447706.23.0
32 pg
…knew the statements were false because Defendant engaged in and
facilitated the sexual abuse of this minor child, therefore, they were made for the inappropriate
purpose of “bullying,” “harassment,” and “intimidation.” See Front v. Khalil, 24 N.Y.3d 713…
giuffre-maxwell
gov.uscourts.nysd.447706.1167.0
31 pg
…These arguments
were made, and documents filed, for purposes of distraction and harassment, and have nothing to
do with the issues presented by the motion. This is classic abuse of the courts records and files.
The Response and Exhibits were…
giuffre-maxwell
1320-28
32 pg
…prostitute I have been the
target of outright lies, innuendo, slander, defamation and salacious gossip and
harassment; headlines made up of quotes I have never given, statements I have
never made, trips with people to places I have never been…
giuffre-maxwell
gov.uscourts.nysd.447706.370.0
17 pg
…Alternatively, such
discovery should be held in abeyance until this Court’s determination of Ms. Maxwell’s motion
for summary judgment.
These requests are made solely for the purpose of harassment and embarrassment of Ms.
Maxwell. Ms. Maxwell requests that…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.19
17 pg
…Alternatively, such
discovery should be held in abeyance until this Court’s determination of Ms. Maxwell’s motion
for summary judgment.
These requests are made solely for the purpose of harassment and embarrassment of Ms.
Maxwell. Ms. Maxwell requests that…
giuffre-maxwell
gov.uscourts.nysd.447706.851.0
158 pg
…under Rule 611 to
13 manage the trial, to avoid undue harassment or embarrassment.
14 Also Rule 403 allows you to restrict things that would be
15 substantially prejudicial with no probative value, which is
16 exactly what we have…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…the independence of the press and the need to allow the press to publish freely on
topics of public interest without harassment and scrutiny by litigants seeking to conduct ‘fishing
expeditions’ into [unpublished] materials in the hope that some relevant…
giuffre-maxwell
gov.uscourts.nysd.447706.872.0
76 pg
…to Giuffre, they were not made in good faith
anticipation of litigation, and instead were made for the
inappropr iate purpose of "bul ly(ing] ," "harass]ment]," and
"intimid[ation]." See Front, 28 N.E.3d at 19 (2015). According…
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