giuffre-maxwell
gov.uscourts.nysd.447706.1320.8
12 pg
…his deposition. Epstein, however, appears to have
no interest in answering questions under oath about the scope of his sex trafficking organization
and he has not authorized his lawyer to accept service of the subpoena. On March 7, 2016, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.17
25 pg
…information protected by the attorney/client privilege, the work-product doctrine, Rule 408 of the
Federal Rules of Evidence, any common interest privilege, joint defense agreement or any other
applicable privilege.
4. Ms. Maxwell objects to the Requests to the…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…opinion, the Second Circuit suggested in dicta that “[t]he District Court may also
order the parties to identify and notify additional parties whose privacy interests would likely be
1
Based on lessons learned from past rounds of unsealing, the…
giuffre-maxwell
1320-8
12 pg
…his deposition. Epstein, however, appears to have
no interest in answering questions under oath about the scope of his sex trafficking organization
and he has not authorized his lawyer to accept service of the subpoena. On March 7, 2016, Ms…
giuffre-maxwell
1320-17
25 pg
…information protected by the attorney/client privilege, the work-product doctrine, Rule 408 of the
Federal Rules of Evidence, any common interest privilege, joint defense agreement or any other
applicable privilege.
4. Ms. Maxwell objects to the Requests to the…
giuffre-maxwell
gov.uscourts.nysd.447706.160.0
12 pg
…his deposition. Epstein, however, appears to have
no interest in answering questions under oath about the scope of his sex trafficking organization
and he has not authorized his lawyer to accept service of the subpoena. On March 7, 2016, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.370.0
17 pg
…life and finances from 2015 to present, including all documents “related
to” her:
tax returns, W-2 or any other source of income statements for her or any entity in which
she holds an interest; Id. at RFP 23…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.19
17 pg
…life and finances from 2015 to present, including all documents “related
to” her:
tax returns, W-2 or any other source of income statements for her or any entity in which
she holds an interest; Id. at RFP 23…
giuffre-maxwell
gov.uscourts.nysd.447706.371.2
18 pg
…information protected by the attorney/client privilege, the work-product doctrine, Rule 408 of the
Federal Rules of Evidence, any common interest privilege, joint defense agreement or any other
applicable privilege.
4. Ms. Maxwell objects to the Requests to the…
giuffre-maxwell
gov.uscourts.nysd.447706.994.0
14 pg
…should also find that Ms.
Maxwell and J. Doe have failed to identify any non-generalized, non-speculative interest that
would outweigh these First Amendment and common law rights of access. Therefore, the
remaining documents should be immediately unsealed with…
giuffre-maxwell
gov.uscourts.nysd.447706.1035.0
2 pg
…aff’d, 814 F.3d 132 (2d Cir. 2016) (disclosing docket
sheets after finding there are no “compelling private interests favoring sealing”). Where a
presumption of the highest weight exists, “[t]he Court is required to order disclosure absent
compelling…
giuffre-maxwell
gov.uscourts.nysd.447706.1036.0
2 pg
…aff’d, 814 F.3d 132 (2d Cir. 2016) (disclosing docket
sheets after finding there are no “compelling private interests favoring sealing”). Where a
presumption of the highest weight exists, “[t]he Court is required to order disclosure absent
compelling…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…of privilege, the work product doctrine, the common interest privilege, or any other privilege or
protection.
Ransome further objects to this Request in that it is vague and ambiguous with respect to
its reference to “all documents” containing communications. Ransome…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…of privilege, the work product doctrine, the common interest privilege, or any other privilege or
protection.
Ransome further objects to this Request in that it is vague and ambiguous with respect to
its reference to “all documents” containing communications. Ransome…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…of privilege, the work product doctrine, the common interest privilege, or any other privilege or
protection.
Ransome further objects to this Request in that it is vague and ambiguous with respect to
its reference to “all documents” containing communications. Ransome…
giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…any Lender or Investor for
the past three years by You personally or on Your behalf or on behalf of any entity in which You
hold or held a controlling interest from January 2015 to the Present.
DOCUMENT REQUEST NO…
Comments