giuffre-maxwell
gov.uscourts.nysd.447706.91.0
3 pg
…Motion to Compel are at once novel (Plaintiff asserts, for
example, a “public interest privilege” which is unavailable to individual, non-governmental
litigants) and mundane (Plaintiff completely refused to answer interrogatories, even though they
comply with the Federal and Local…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.28_4
5 pg
…5
due to.. VR ..lack of credibility "
The new interest in this old settled case results from lawyers representing
some of JE victims filed a suit against the US government not JE . They
contend that the Us govt violated their…
giuffre-maxwell
gov.uscourts.nysd.447706.1211.0_1
5 pg
…Maxwell’s motion is
denied.
I. Legal Standard
“A motion for reconsideration is an extraordinary remedy to
be employed sparingly in the interests of finality and
conservation of scarce judicial resources.” Drapkin v. Mafco
1 (Letter from Laura Menninger (“Mot.”)…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.21
8 pg
…Gow Ghislaine Maxwell Brian Attorney Agent / Communication re: Attorney-Client
Basham Client legal advice
2015.01.06 E-Mail Ghislaine Maxwell Jeffrey Epstein Common Inte…
giuffre-maxwell
gov.uscourts.nysd.447706.35.1
4 pg
…protected by the attorney/client
privilege, the work-product doctrine, the common interest privilege or any other applicable
privilege.
Subject to and without waiving the above objections, Maxwell is withholding documents
outside of the Relevant Periods described in paragraph15, supra…
giuffre-maxwell
gov.uscourts.nysd.447706.55.11
3 pg
…Gow Ghislaine Maxwell Brian Attorney Agent / Communication re: Attorney-Client
Basham Client legal advice
2015.01.06 E-Mail Ghislaine Maxwell Jeffrey Epstein Common Inte…
giuffre-maxwell
gov.uscourts.nysd.447706.156.3
9 pg
…Work Product/joint
2/16/2015 [email protected],robiej defense/common
2 1:05 [email protected] [email protected] Discussion of evidence among client and attorneys interest Wit…
giuffre-maxwell
gov.uscourts.nysd.447706.139.0
7 pg
…pursuant to the Court’s Order [DE 134] dated May 2, 2016.1
ARGUMENT
Statements made by witnesses to law enforcement are protected by the public interest
privilege, which “exists to encourage witnesses to come forward and provide information in…
giuffre-maxwell
gov.uscourts.nysd.447706.981.0
2 pg
…the
Maxwell records was to give the Jeffrey Epstein network the attention it deserved. Mr.
Cernovich had informed many members of the press that Epstein had escaped justice,
with little to no interest from them. Other than a May 4…
giuffre-maxwell
gov.uscourts.nysd.447706.722.0
6 pg
…from Sarah Kellen and Nadia Marcinkova for
Purposes of Obtaining an Adverse Inference (DE 698). In the interest of brevity before the Court,
Ms. Giuffre adopts all of the facts and arguments from the aforementioned motion and
incorporates them herein…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.6
8 pg
…Gow Ghislaine Maxwell Brian Attorney Agent / Communication re: Attorney-Client
Basham Client legal advice
2015.01.06 E-Mail Ghislaine Maxwell Jeffrey Epstein Common Inte…
giuffre-maxwell
gov.uscourts.nysd.447706.235.2
4 pg
…May 3rd,
please provide the following documents on or before April 27th, 2016.
All documents withheld on the basis of the “public interest privilege,” other
than Plaintiff’s actual statements to any law enforcement agency, which are to
be…
giuffre-maxwell
gov.uscourts.nysd.447706.156.2
4 pg
…28/2015 Email with Giuffre, McCawley, Edwards and defense/common
19 17:47 Virginia Giuffre [email protected] Henderson re discussion of draft statement interest Withheld 3 msg
…
giuffre-maxwell
gov.uscourts.nysd.447706.156.8
5 pg
…with Giuffre, Edwards, Pottinger and interest/work
30 18:40 Stan [email protected] McCawley re legal advice related to VRS product Withheld 1 msg
…
giuffre-maxwell
gov.uscourts.nysd.447706.156.6
3 pg
…McCawley and legal assistant re seeking Work Product/joint
5/4/2015 information to assist in providing legal advice, with defense/common
81 20:04 Virginia Giuffre [email protected] attachment …
giuffre-maxwell
gov.uscourts.nysd.447706.1249.0
1 pg
…93, and 151. The parties to this action and other
interested parties are invited to appear telephonically for the
Court’s rulings as to these objections on Tuesday April 19,
2022, at 10:30 a.m., using the following information…
giuffre-maxwell
gov.uscourts.nysd.447706.1350.0
1 pg
…of court and all parties of record
I am admitted or otherwise authorized to practice in this court, and I appear in this case as counsel for:
Interested Party J Doe 12 .
Date: 12/01/2025 …
giuffre-maxwell
gov.uscourts.nysd.447706.1227.0
2 pg
…Parties.
First, Doe criticizes the Original Parties’ compliance with the Court’s unsealing orders and
directives to redact the names of non-parties whose interests the Court has not yet considered,
which has involved an immense amount of resources. ECF…
giuffre-maxwell
gov.uscourts.nysd.447706.1271.0
1 pg
…171, and 183. The parties to this action and other
interested parties are invited to appear telephonically for the
Court’s rulings as to these objections on Friday November 18,
2022, at 11 a.m., using the following information: dial…
giuffre-maxwell
gov.uscourts.nysd.447706.977.2
1 pg
…task. As the Court’s opinion recognizes in connection with the remaining
sealed materials, the district court is better positioned to communicate with the
parties and any nonparties whose privacy interests might be affected by
unsealing. On that score, it…
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