giuffre-maxwell
gov.uscourts.nysd.447706.1328.40
3 pg
…of the government to act
appropriately and violate our rights as victims by giving Jeffrey Epstein a plea lxirgain and immunity to only take accreditation for one account of the
sensi ti ve subject of procuring us undernge gi rls…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.42
9 pg
…related to another lawsuit. And normally, anything you
say in a court document relating to a pending lawsuit is, there's immunity. You can't
sue somebody for saying that. So Dershowitz was baiting Roberts saying, why don't
you…
giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…to the court with the intent that it will be unsealed
by the court so that she can use it for profit with “absolute immunity from liability” because it
was submitted “in connection with a proceeding before a court,” Brown…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…first be established in order to determine the
interest to be balanced against that of a civil litigant. Full disclosure is the general rule and the
burden of showing immunity from disclosure is on the party asserting it”); People v…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…role in negotiating the NPA on Epstein’s behalf.
Indeed, Dershowitz helped negotiate an agreement that provided immunity from federal
prosecution in the Southern District of Florida not only to Epstein, but also to “any potential co-
conspirators of Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…unusual non-
prosecution agreement (negotiated by, among others, Epstein defense attorney
Alan Derhsowitz) that provided immunity from prosecution for sex trafficking not
only to Epstein but also to his "potential co-conspirators";
• One of Epstein's household employees, Juan Alessi…
giuffre-maxwell
gov.uscourts.nysd.447706.35.1
4 pg
…enforcement entity, or from any
law enforcement entity to you or any of your representatives related to any cooperation, potential
charge, immunity or deferred prosecution, or which relates to suspected or known criminal
activity.
ii. Maxwell’s Response:
Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…publications, this threat is non‐
existent with respect to certain court filings. This is so because, under
New York law (which governs the underlying defamation claim here),
“absolute immunity from liability for defamation exists for oral or
written statements made . . …
giuffre-maxwell
gov.uscourts.nysd.447706.1218.31
10 pg
…particularly derelict in failing to note the pivotal role of
Alan Dershowitz, Israel's most aggressive defender, in securing near impunity for a sexual predator and his accomplices by
bullying, harassing, intimidating and smearing child victims of rape.
Unprecedented Impunity…
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…noting that the Government “may institute or continue a grand
jury proceeding,” “subpoena witnesses to testify,” or, where
witnesses invoke their Fifth Amendment privilege, “offer immunity
in exchange for their testimony”). However, this principle holds
true even in civil matters…
giuffre-maxwell
gov.uscourts.nysd.447706.179.0
22 pg
…addressees, a short description of each document
and the privilege or immunity asserted with respect to each. Submissions by the parties in
connection with this motion have made clear the relationship of authors and addressees to each
other with respect…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…related to any cooperation,
potential charge, immunity or deferred prosecution, or which relates to suspected or known
criminal activity.
8
Case 1:15-cv-07433-RWS Document 17-1 Filed 12/01/15 Page 9 of 13
DOCUMENT REQUEST…
giuffre-maxwell
gov.uscourts.nysd.447706.99.0
22 pg
…the alleged abuse might be responsible for plaintiff’s psychiatric condition).
As held in the cases cited by Plaintiff “[t]he burden of demonstrating that certain records
are immune from discovery is on the party asserting such immunity” Wachtman v…
giuffre-maxwell
1320-9
10 pg
…role in negotiating the NPA on Epstein’s behalf.
Indeed, Dershowitz helped negotiate an agreement that provided immunity from federal
prosecution in the Southern District of Florida not only to Epstein, but also to “any potential co-
conspirators of Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.8
29 pg
…1418, 2015 WL 1539051, at *4 (N.D. Ill. Mar. 31, 2015) (joint-defense
agreement was protected from disclosure by common interest doctrine and attorney work product
immunity); Heartland Surgical Specialty Hosp. v. Midwest Div., No. 05-2164-MLB-DWB…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…publications, this threat is non‐
existent with respect to certain court filings. This is so because, under
New York law (which governs the underlying defamation claim here),
“absolute immunity from liability for defamation exists for oral or
written statements made . . …
giuffre-maxwell
gov.uscourts.nysd.447706.978.0
27 pg
…publications, this threat is non‐
existent with respect to certain court filings. This is so because, under
New York law (which governs the underlying defamation claim here),
“absolute immunity from liability for defamation exists for oral or
written statements made . . …
giuffre-maxwell
gov.uscourts.nysd.447706.1330.1
13 pg
…highly unusual non-
prosecution agreement (negotiated by, among others, Epstein defense attorney
Alan Dershowitz) that provided immunity from prosecution for sex trafficking
not only to Epstein but also to his “potential co-conspirators”;
k. One of Epstein’s household employees…
giuffre-maxwell
gov.uscourts.nysd.447706.589.0
24 pg
…1308 (7th Cir. 1984)
Only reasons given for maintaining confidentiality: attorney-client
privilege, work product immunity and effective functioning of special
litigation committees. By contrast, protecting minor victims of sexual
assau…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.45
13 pg
…highly unusual non-
prosecution agreement (negotiated by, among others, Epstein defense attorney
Alan Dershowitz) that provided immunity from prosecution for sex trafficking
not only to Epstein but also to his “potential co-conspirators”;
k. One of Epstein’s household employees…
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