giuffre-maxwell
gov.uscourts.nysd.447706.1074.0
18 pg
…action.” (Id. at 3, 7). Specifically, Jane Doe 3 proffers that she could prove
the circumstances under which a non-party introduced her to Mr. Epstein, and how Mr. Epstein
sexually trafficked her to several high-profile non-party individuals, …
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.447706.185.4
10 pg
…action.” (Id. at 3, 7). Specifically, Jane Doe 3 proffers that she could prove
the circumstances under which a non-party introduced her to Mr. Epstein, and how Mr. Epstein
sexually trafficked her to several high-profile non-party individuals, …
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.447706.363.4
11 pg
…action.” (Id. at 3, 7). Specifically, Jane Doe 3 proffers that she could prove
the circumstances under which a non-party introduced her to Mr. Epstein, and how Mr. Epstein
sexually trafficked her to several high-profile non-party individuals, …
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.447706.1074.5
11 pg
…action.” (Id. at 3, 7). Specifically, Jane Doe 3 proffers that she could prove
the circumstances under which a non-party introduced her to Mr. Epstein, and how Mr. Epstein
sexually trafficked her to several high-profile non-party individuals, …
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…NY 10504
Case 1:15-cv-07433-LAP Document 1320-18 Filed 01/03/24 Page 2 of 40
TABLE OF CONTENTS
TABLE OF CONTENTS.....................…
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
1320-18
40 pg
…NY 10504
Case 1:15-cv-07433-LAP Document 1320-18 Filed 01/03/24 Page 2 of 40
TABLE OF CONTENTS
TABLE OF CONTENTS.....................…
giuffre-maxwell
gov.uscourts.nysd.447706.962.0
7 pg
…plaintiff Virginia Giuffre and her lawyers to state
why this Court should not impose sanctions for their failure to comply with the Court’s
Protective Order.
INTRODUCTION
The Protective Order requires the destruction or return of all “Confidential”-designated
materials…
giuffre-maxwell
gov.uscourts.nysd.447706.526.0
5 pg
…MORGAN, AND FOREMAN, P.C.
150 East 10th Avenue
Denver, CO 80203
303…
giuffre-maxwell
gov.uscourts.nysd.447706.562.1
13 pg
…pertinent part, the Jane Doe No. 102 complaint described in detail how
Maxwell recruited Giuffre (who was then a minor girl) to become a victim of sex trafficking by
introducing Giuffre to Jeffrey Epstein. With the assistance of Maxwell, Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1.0
12 pg
…pertinent part, the Jane Doe No. 102 complaint described in detail how
Maxwell recruited Giuffre (who was then a minor girl) to become a victim of sex trafficking by
introducing Giuffre to Jeffrey Epstein. With the assistance of Maxwell, Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.24.1
13 pg
…pertinent part, the Jane Doe No. 102 complaint described in detail how
Maxwell recruited Giuffre (who was then a minor girl) to become a victim of sex trafficking by
introducing Giuffre to Jeffrey Epstein. With the assistance of Maxwell, Epstein…
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