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.447706.562.1
13 pg
…Epstein.
13. As a co-conspirator of Epstein, Maxwell was consequently granted immunity in
the Southern District of Florida through the NPA.
14. Epstein ultimately pled guilty to procuring a minor for prostitution, and is now a
registered sex offender…
giuffre-maxwell
gov.uscourts.nysd.447706.1.0
12 pg
…Epstein.
13. As a co-conspirator of Epstein, Maxwell was consequently granted immunity in
the Southern District of Florida through the NPA.
14. Epstein ultimately pled guilty to procuring a minor for prostitution, and is now a
registered sex offender…
giuffre-maxwell
gov.uscourts.nysd.447706.24.1
13 pg
…Epstein.
13. As a co-conspirator of Epstein, Maxwell was consequently granted immunity in
the Southern District of Florida through the NPA.
14. Epstein ultimately pled guilty to procuring a minor for prostitution, and is now a
registered sex offender…
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.447706.35.1
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.447706.1218.31
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.447706.179.0
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.447706.99.0
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
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.447706.370.0
17 pg
…v. New York State Consumer Protection Bd., 237 F.R.D. 325
(N.D.N.Y 2006) (personal financial information is “presumptively confidential or cloaked with a
qualified immunity”); see also Statharos v. New York City Taxi and Limousine Commission…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.19
17 pg
…v. New York State Consumer Protection Bd., 237 F.R.D. 325
(N.D.N.Y 2006) (personal financial information is “presumptively confidential or cloaked with a
qualified immunity”); see also Statharos v. New York City Taxi and Limousine Commission…
giuffre-maxwell
gov.uscourts.nysd.447706.354.0
40 pg
… even if it were, the Court’s Protective Order more
than adequately protects that right. As to assertions of privilege or immunity over any responsive
document, to the extent any privilege or immunity applies, Plaintiff must comply with her duties…
giuffre-maxwell
gov.uscourts.nysd.447706.1248.0
6 pg
…allowed to conceal from the
public. It is vitally important for the public to understand how the sex trafficking of young girls by
the wealthy and powerful was able to persist for years with impunity. And any adults who
participated…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.0
9 pg
…Five, no one should be permitted to violate this Court’s Protective
Order with impunity.
As it did in connection with plaintiff’s violation of the Protective Order via her attorneys, the
Court should enter orders to determine the nature…
giuffre-maxwell
gov.uscourts.nysd.447706.79.2
18 pg
…A lld ocu ments from you ,you rattorneys oragents to any law
enforcemententity,orfrom any law enforcemententity to you orany of you rrepresentatives
related to any cooperation,potentialcharge,immu nity ord eferred prosecu tion,orwhichrelates
to su spected orknown criminalactivity.
…
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