giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…are
among the best records of Plaintiff’s lies. They are public documents and there is no good faith
basis for Plaintiff’s attempt to render them hidden from public view, in her public lawsuit
designed to promote her well…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.6_1
14 pg
…are
among the best records of Plaintiff’s lies. They are public documents and there is no good faith
basis for Plaintiff’s attempt to render them hidden from public view, in her public lawsuit
designed to promote her well…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…1053 at 1. Neither Doe 1 nor
Doe 2 requested excerpts of the sealed materials that mention their names, and Maxwell has not
identified any compelling reason to continue to keep their identities hidden. In fact, Doe 1 and
Doe…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…all emails—whether saved or deleted –
and irrespective of which account they came from; not a single responsive email was located
from any Mindspring account and no emails were located from Earthlink or any other secret,
hidden, “undisclosed” email account…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…all emails—whether saved or deleted –
and irrespective of which account they came from; not a single responsive email was located
-
from any Mindspring account and no emails were located from Earthlink or any other secret,
hidden, “undisclosed” email account…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.33
24 pg
…discoverable, and was purposefully hidden by Plaintiff.
Any action short of precluding claims for physical, psychological and emotional distress
damages will fall short of serving Rule 37’s purpose to “ensure that a party will not benefit from
its own…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.16
30 pg
…Dr. Donahue.
Additionally, Defendant acts in bad faith when she claims that medical records from Dr.
Donahue were “purposefully hidden by Plaintiff” (Mtn. at 11) when Defendant knows that Ms.
Giuffre executed and sent a medical release for Dr. Donahue…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.18
50 pg
…2016, Subpoenas to Churcher and Weissfeld.
Yet, Defendant cited a number of cases wherein discovery was buried amid voluminous
productions so as to be hidden or to cause delayed or cumbersome discovery of them. They are
inapposite. Defendant didn’t…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.1_2
24 pg
… disclosed June 1
Shopper’s Paradise – subpoena notice April 26; never disclosed
How many other witnesses are there with relevant information that Plaintiff has hidden?
5
No ruling had been made on this Motion.
12
Case 1:15…
giuffre-maxwell
gov.uscourts.nysd.447706.230.0
19 pg
…to relevant discovery.
7
Case 1:15-cv-07433-LAP Document 230 Filed 06/20/16 Page 11 of 19
It is completely unknown what other relevant and probative information will be
uncovered in Plaintiff’s previously hidden accounts…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.7
30 pg
…Dr. Donahue.
Additionally, Defendant acts in bad faith when she claims that medical records from Dr.
Donahue were “purposefully hidden by Plaintiff” (Mtn. at 11) when Defendant knows that Ms.
Giuffre executed and sent a medical release for Dr. Donahue…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.5_2
30 pg
…Dr. Donahue.
Additionally, Defendant acts in bad faith when she claims that medical records from Dr.
Donahue were “purposefully hidden by Plaintiff” (Mtn. at 11) when Defendant knows that Ms.
Giuffre executed and sent a medical release for Dr. Donahue…
giuffre-maxwell
gov.uscourts.nysd.447706.659.0
7 pg
…s Order
Continued conferral by Ms. Giuffre’s
counsel regarding the hidden email accounts was unavailing.
An adverse inference instruction is appropriate when a party refuses to turn over documents
in defiance of a Court Order. See Lyondell-Citgo Refining…
giuffre-maxwell
1320-33
24 pg
…discoverable, and was purposefully hidden by Plaintiff.
Any action short of precluding claims for physical, psychological and emotional distress
damages will fall short of serving Rule 37’s purpose to “ensure that a party will not benefit from
its own…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.19
30 pg
…the practice of courts viewing such
testimony as false and intentionally evasive, and as a sham or subterfuge that purposely avoids
17
deliberately “withheld” or “hidden” are things that Ms. Giuffre provided to Defendant in the
normal course of discovery…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.12_3
30 pg
…cv-07433-LAP Document 1198-12 Filed 01/27/21 Page 22 of 30
Case 1:15-cv-07433-LAP Document 1198-12 Filed 01/27/21 Page 23 of 30
deliberately “withheld” or “hidden” are things that Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.1
18 pg
…Defendant should produce the requested
documents. If such documents were obtained in contravention of Florida Statutes, it cannot be
hidden behind a production of later-acquired police reports. Accordingly, the Court should
compel production of these documents.
5
ii…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.14
30 pg
…Dr. Donahue.
Additionally, Defendant acts in bad faith when she claims that medical records from Dr.
Donahue were “purposefully hidden by Plaintiff” (Mtn. at 11) when Defendant knows that Ms.
Giuffre executed and sent a medical release for Dr. Donahue…
giuffre-maxwell
gov.uscourts.nysd.447706.231.0
23 pg
…discoverable, and was purposefully hidden by Plaintiff.
Any action short of precluding claims for physical, psychological and emotional distress
damages will fall short of serving Rule 37’s purpose to “ensure that a party will not benefit from
its own…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.11
18 pg
…in fact, haven't you read many of
8 these newspaper articles?
9 A. That is correct.
10 Q. That was not a hidden secret from the
11 public beginning in 2006, right?
12 A. No.
13 Q. And from…