giuffre-maxwell
gov.uscourts.nysd.447706.1328.18
50 pg
… This Discovery is Barred by FRE 412......................................................20
2. This Request if Propounded for Improper Purposes and Harassment ......21
3. This Request Seeks Irrelevant Information ..............................................22
…
giuffre-maxwell
gov.uscourts.nysd.447706.20.0
26 pg
…7
1. The Qualified “Self-Defense” Privilege Does Not Protect
The Publication Of Deliberately False Statements......................................8
2. The Qualified Pre-Litigation Privilege Does Not Protect
Mass Publication Of D…
giuffre-maxwell
gov.uscourts.nysd.447706.363.6
15 pg
…April 4, 2011) (trial court
granting protective order precluding a deposition noting “this deposition request is mere
harassment” and had no relevance to the underlying dispute where the party was wrongfully using
the discovery process for personal gain).
b. Category…
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.447706.1328.5
45 pg
…not to mention the purposes of harassment.
12
Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 14 of 45
This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
Pursuant to…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…asserts, without factual or legal support, that her financial
information is being sought “for the purpose of harassment and intimidation.” Because Ms.
Ransome failed to address the relevance argument asserted by the Motion, this issue should be
deemed admitted. Compare…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.9
15 pg
…asserts, without factual or legal support, that her financial
information is being sought “for the purpose of harassment and intimidation.” Because Ms.
Ransome failed to address the relevance argument asserted by the Motion, this issue should be
deemed admitted. Compare…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…own, your Honor, doesn't seem to require a
3 nonparty witness to go through those burdensome and harassment
4 lengths.
5 THE COURT: But those statements have nothing to do
6 with this case.
7 MR. POTTINGER: Well, not…
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.447706.1328.4
40 pg
…such an interrogatory
is merely for the purpose of imposing a burden on Ms. Giuffre and her attorneys,
not to mention the purposes of harassment.
Pursuant to the Rules, if requested documents are not yielded in a “reasonable
inquiry,” Ms…
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.447706.1137.19_2
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.447706.851.0
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.447706.354.0
40 pg
…the
extent any right of privacy is applicable, the Court’s Protective Order affords Plaintiff all the
privacy to which she is entited.
Objection 11.
There is no “harassment.” Federal Rule of Evidence 412, commonly referred to as the
rape…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.22
22 pg
…the target of outright lies, innuendo, slander, defamation and salacious
gossip and harrasment; headlines made up of quotes I have never given,
statements I have never made, trips with people to places I have never
been, holidays with people I…
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