giuffre-maxwell
gov.uscourts.nysd.447706.1331.32
4 pg
… 1n the summer of 2006, when I was twenty-two years old and living in New York,
I was introduced to Jeffrey Epstein by a girl I had met named Natalya.
Malyshov. Shortly after meeting Jeffrey he invited me to…
giuffre-maxwell
gov.uscourts.nysd.447706.34.2
3 pg
…who are
sharing connections, ideas, and opportunities.
• See who you know in common
• Get introduced
• Contact Ross directly
Experience
Owner, Managing Partner
ACUITY Reputation
January 2010 – Present (6 years 2 months)
ACUITY advises Governments, Corporates and UHNWIs on reputational issues…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.14_2
40 pg
…Armonk, NY 10504
Case 1:15-cv-07433-LAP Document 1137-14 Filed 10/22/20 Page 2 of 40
TABLE OF CONTENTS
TABLE OF CONTENTS............................................................................................................................... i
TABLE OF AUTHORITIES ...........…
giuffre-maxwell
gov.uscourts.nysd.447706.903.0
46 pg
…and now there is going to be this attempt, I think, to
8 introduce what I view as a hearsay document without foundation
9 into this trial through that deposition.
10 That, I think, primarily deals --
11 THE COURT: Through…
giuffre-maxwell
gov.uscourts.nysd.447706.561.0
22 pg
…...........................5
B. The Florida State Case Did Not Involve the Same Parties.........................................6
II. THE COURT SHOULD USE ITS DISCRETION TO PRECLUDE INTRODUCTION
OF TESTIMONY FROM A WITNESS MS. GIUFFRE HAS NOT HAD THE
OPPORTUNITY TO CROSS EXAMINE. .........…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…person; (4) the strength of any property and
privacy interests asserted; (5) the possibility of prejudice to those opposing
disclosure; and (6) the purposes for which the documents were introduced during
the judicial proceedings.
United States v. Harris, 204 F…
giuffre-maxwell
gov.uscourts.nysd.447706.1126.0
3 pg
…unsealing of
the deposition materials. While “the presumption of public access in filings submitted in connection
with discovery disputes or motions in limine is generally somewhat lower than the presumption
applied to material introduced at trial, or in connection with…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…in
Palm Beach. See McCawley Decl. at Exhibit 6, Maxwell Depo. at 29.
Whether Defendant had meet Ms. Giuffre and introduced her to Epstein. Id. at 33.
Whether Defendant, in 2011, could recall having met Ms. Giuffre at…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…in
Palm Beach. See McCawley Decl. at Exhibit 6, Maxwell Depo. at 29.
! Whether Defendant had meet Ms. Giuffre and introduced her to Epstein. Id. at 33.
! Whether Defendant, in 2011, could recall having met Ms. Giuffre at the Mar…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…1625
of 25
monitoring the federal courts.”29 Thus, while evidence introduced at
trial or in connection with summary judgment enjoys a strong
presumption of public access, documents that “play only a negligible
role in the performance of Article III…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…in
Palm Beach. See Mccawley Deel. at Exhibit 6, Maxwell Depo. at 29.
• Whether Defendant had meet Ms. Giuffre and introduced her to Epstein. Id. at 33.
• Whether Defendant, in 2011, could recall having met Ms. Giuffre at the Mar…
giuffre-maxwell
1320-10
28 pg
…in
Palm Beach. See McCawley Decl. at Exhibit 6, Maxwell Depo. at 29.
! Whether Defendant had meet Ms. Giuffre and introduced her to Epstein. Id. at 33.
! Whether Defendant, in 2011, could recall having met Ms. Giuffre at the Mar…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…25
of 25
monitoring the federal courts.”29 Thus, while evidence introduced at
trial or in connection with summary judgment enjoys a strong
presumption of public access, documents that “play only a negligible
role in the performance of Article III…
giuffre-maxwell
gov.uscourts.nysd.447706.978.0
27 pg
…of
2527
monitoring the federal courts.”29 Thus, while evidence introduced at
trial or in connection with summary judgment enjoys a strong
presumption of public access, documents that “play only a negligible
role in the performance of Article III duties…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.13
35 pg
…there's
12 a good-faith basis.
13 Q. Did you approach Alan
14 Dershowitz for the purpose of seeking
15 legal advice?
16 A. I was introduced to Alan.
17 Q. By whom?
18 A. Jeffrey Epstein.
19 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.977.0
27 pg
…1625
of 25
monitoring the federal courts.”29 Thus, while evidence introduced at
trial or in connection with summary judgment enjoys a strong
presumption of public access, documents that “play only a negligible
role in the performance of Article III…
giuffre-maxwell
gov.uscourts.nysd.447706.46.0
22 pg
…PRIVILEGE
Laura A. Menninger
HADDON, MORGAN, AND FOREMAN, P.C.
East 10th Av…
giuffre-maxwell
gov.uscourts.nysd.447706.179.0
22 pg
…954) 356-0011
David Boies
Boies Schiller & Flexner LLP
333 Main Street
Armonk, NY 10504
Case 1:15-cv-07433-LAP Document 179 Filed 05/31/16 Page 2 of 22…
giuffre-maxwell
gov.uscourts.nysd.447706.63.0
22 pg
…AND FOREMAN, P.C.
East 10th Avenue
Denver, CO 80203
303.831.7364
…
giuffre-maxwell
gov.uscourts.nysd.447706.222.0
10 pg
…to the accompanying Declaration of Gregory L. Poe
(“Poe Decl.”) as Exhibit 1. Mr. Epstein respectfully requests a hearing on this motion.
INTRODUCTION
As Mr. Epstein’s counsel has repeatedly informed counsel for plaintiff, Mr. Epstein will
invoke his Fifth…
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