giuffre-maxwell
gov.uscourts.nysd.447706.34.2
3 pg
…who are
sharing connections, ideas, and opportunities.
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giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…1:15-cv-07433-LAP Document 1073 Filed 07/01/20 Page 2 of 22
Introduction
This Court asked the parties to brief three issues: “(a) the weight of presumption of
public access that should be afforded to an item…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.43
8 pg
…him to England to
20 Q. Rodriguez stated Epstein did not want to 20 introduce him to the royalty.
21 see or hear the staff when he was in the 21 Q. Is it's your understanding that Ghislaine
22 …
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…relate solely to five-year-old discovery disputes and therefore, at most,
begin with a presumption of public access “somewhat lower than the presumption applied to
material introduced at trial, or in connection with dispositive motions such as motions for…
giuffre-maxwell
gov.uscourts.nysd.447706.363.0
18 pg
…Jeffrey Epstein, a financier who was accused of soliciting sex workers and having
inappropriate sexual conduct with underage girls, was a client of mine. I first was introduced to
Mr. Epstein by a friend, Lynn Forester de Rothschild, in 1997…
giuffre-maxwell
gov.uscourts.nysd.447706.555.0
21 pg
…I Defendant Ghislaine Maxwell ("Ms. Maxwell") hereby submits this Motion for Sanctions
I Based on Plaintiffs Intentional Destruction of Evidence and further states as follows:
I INTRODUCTION
In 2013 , after Plaintiff was in the process of attempting to join the…
giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…Epstein, who was not a defendant. She tried to do so by seeking to introduce
evidence wholly irrelevant to her defamation claim. See Doc.991 at 6-7. Plaintiff claims not to
5
Case 1:15-cv-07433-LAP…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…she was not 15 years old, she now
has conclusive proof that she was an underage minor when Ghislaine Maxwell approached her,
recruited her, introduced her to Jeffrey Epstein, and sexually trafficked her as an underage minor.
2. Admit that…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…two
lawyers went from attacking each other and calling each other liars, to Dershowitz’s nostalgic invitation,
referring to Boies as “an old friend” who he was introduced to years ago through the late Sen. Ted Kennedy
(DMass.).
“It has…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…in
13 Florida. So it was a document in that case -- in discovery in
14 that case as well, and that's why we have testimony on --
15 THE COURT: Was it introduced in that case?
16 MS. McCAWLEY: It…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…she
intends to salvage her liberty and reputation against claims that she supplied depraved
Epstein with young girls.
Maxwell’s allies have told The Mail on Sunday that she:
Is not the person who introduced billionaire Epstein to Prince Andrew…
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.447706.1335.3
223 pg
… The court reporter is Deborah
18 Harris, both from Esquire Deposition Solutions.
19 Would counsel please introduce yourselves and your
20 affiliation and the witness will be sworn in.
21 MS. MCCAWLEY: My name is Sigrid McCawley.
22 I'm…
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.447706.1149.0
18 pg
…315, 320, & 335, and states as
follows:
Introduction
Ms. Maxwell submits this Memorandum of Law in support of her objection to the
unsealing of her July 22, 2016 deposition testimony, any excerpts of that testimony and any
pleadings that quote…
giuffre-maxwell
gov.uscourts.nysd.447706.223.1
14 pg
…or companionship for You.
18. All Documents relating to any females Ghislaine Maxwell introduced to You.
19. A 11 Documents relating to any females You paid to perform any kind of service,
10
Case 1:15-cv-07433-RWS…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…Ms. Maxwell -- I am not understanding
11 precisely the court's question, but I think if the court is
12 talking about it being introduced into evidence in the trial or
13 for some other purpose?
14 THE COURT: Well…
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.447706.1332.16
16 pg
…which I have managed to save. They include the
following:
I moved from Edinburgh to
New York in September 2006, where shortly after I was introduced to Jeffery Epstein by Natalie.
. A couple months later, after he constantly stalked me…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.12
223 pg
… The court reporter is Deborah
18 Harris, both from Esquire Deposition Solutions.
19 Would counsel please introduce yourselves and your
20 affiliation and the witness will be sworn in.
21 MS. MCCAWLEY: My name is Sigrid McCawley.
22 I'm…
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