giuffre-maxwell
gov.uscourts.nysd.447706.1295.14
6 pg
…Dustin Hoffman, Michael Bloomberg and Richard Branson.
Bill Clinton in 1994.
AP
ln a 2006 court filing, Palm Beach police noted that a search of Epstein's home uncovered two hidden
cameras. The Mirror reported that in 2015, a 6…
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.447706.363.11
40 pg
…Rankings ABOVE THE LAW LAWYER MARKETING LAWYER MARKETING
ABOVE THE LAW
Case 1:15-cv-07433-LAP Document 363-11 Filed 08/11/16 Page 8 of 40
6 comments
(hidden for your protection)
comments sponsored by
SHOW…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…materials.” Brown, supra at 45. Although TGP is appreciative of the Court’s efforts to
unseal since that decision, the most crucial information that the public is demanding to know
remains hidden. Though it may be possible that, somehow, no…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…example, if Defendant were to testify at trial she had a
net worth of only ten million dollars – and not provide information about where she had hidden
the fifteen million dollars associated with the sale of her apartment – then Ms…
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.447706.1328.23
22 pg
…example, if Defendant were to testify at trial she had a
net worth of only ten million dollars – and not provide information about where she had hidden
the fifteen million dollars associated with the sale of her apartment – then Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.43.0
15 pg
…result
in an unmanageable number of documents. Instead, Defendant is picking and choosing which
documents she will produce, and which documents she will keep hidden. She’s not making this
determination based on responsiveness, or based on undue burden, but…
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.447706.1219.1
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.447706.185.8
24 pg
…that is
vital to his defense – the third prong in the tri-part test. To date, Plaintiffs have hidden behind
the attorney-client privilege to selectively produce evidence regarding their conversations,
emails, and/or interviews with Giuffre. As noted above…
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.447706.1325.11
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…
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