giuffre-maxwell
gov.uscourts.nysd.447706.1046.0
3 pg
…multiple times to propose five motions pertaining to J. Doe 1 and J. Doe 2, as
identified on the sealed Non-Party List, with which the Court may begin administering the Order
and Protocol for Unsealing Decided Motions, Dkt. 1044…
giuffre-maxwell
gov.uscourts.nysd.447706.303.0
13 pg
…33. She strenuously argues that she has
“disclosed” various treatment providers because their names are buried in records that she has
belatedly produced and which she obtained only after defense counsel had identified their
existence and absence through independent investigation…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.25_1
13 pg
…33. She strenuously argues that she has
“disclosed” various treatment providers because their names are buried in records that she has
belatedly produced and which she obtained only after defense counsel had identified their
existence and absence through independent investigation…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…plainly unreasonable.
Finally, it bears emphasizing that virtually all of the prominent individuals accused by
Giuffre concerning whom Dershowitz seeks discovery have already been publicly identified by
name in deposition testimony which has been unsealed in Maxwell. See Exhibit A…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.3_1
4 pg
…84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
Case 1:15-cv-07433…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.27
11 pg
…served on plaintiff’s counsel Ms. Maxwell’s Initial Fed. R.
Civ. P. 26(a)(1)(A) Disclosures. The third-listed individual we identified who “likely [has]
discoverable information” was Philip Barden, who, we disclosed, had information “concerning
press statements . . …
giuffre-maxwell
gov.uscourts.nysd.447706.1320.25
4 pg
…UT 84112
(801) 585-52022
2
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.751.10
4 pg
…sexual contact ever took place
between the pair as "false and hurtful to me."
Interview request
The woman, identified by Buckingham Palace as Virginia Roberts, first named the prince in a civil motion filed
December 30 in the U.S…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.10
23 pg
…LAP Document 1328-10 Filed 01/05/24 Page 4 of 23
Confidential
Page 2 0
1 G. Maxwell - Confidential
2 anyone in any of Mr. Epstein ' s five homes
3 that you have identified?
4 A. Yes .
5 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…here will unfairly prejudice Ms.
Maxwell’s rights to a fair trial by poisoning any venire and influencing witness testimony. For
reasons discussed below, the Court should decline to unseal the identified Sealed Items.
I. Ms. Maxwell’s July 22…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.46
14 pg
…and other witness testimony contradict Plaintiff’s
deposition ......................................................................................................................... 5
E. Plaintiff identified new witnesses in her Rule 26 disclosures after her deposition .......... 6
II. PLAINTIFF’S COUNSEL IN…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.22
3 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1067.0
10 pg
…the alleged countervailing interests that are insufficient to
outweigh the presumption of access to these judicial documents.
As set forth in detail below, there is no basis identified in the Objections for the Court to
continue sealing Dkt. Entries 143…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.23
3 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.153.0
4 pg
…84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
Case 1:15-cv-07433…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…explained why they waited more than two
months to disclose the witness, nor why they represented to the Court that she was a “recent” discovery.
1
BACKGROUND
Plaintiff first identified Sarah Ransome as a witness on January 13, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.33
24 pg
…has not provided this information to date. It is only
through deposition testimony that Ms. Maxwell became aware of at least five – if not more –
treating health care providers who were never previously identified. Yet, Plaintiff has never
supplemented her…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.4
23 pg
…Clerk of Court by using the CM/ECF system. I also certify that the foregoing
document is being served this day on the individuals identified below via transmission of Notices
of Electronic Filing generated by CM/ECF.
Laura A. Menninger…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.16
10 pg
…defense case-in-chief. In light of the well settled rules
that a rebuttal expert is “intended solely to contradict or rebut evidence on the same subject
matter identified” in the expert report of another party, there would be no…
giuffre-maxwell
gov.uscourts.nysd.447706.1083.0
3 pg
…produced or answered discovery based on the understanding that
such discovery would be subject to the Protective Order, (b) persons who are identified as
allegedly having engaged in sex acts with Plaintiff or other alleged victims, or facilitated such
acts…
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