giuffre-maxwell
gov.uscourts.nysd.447706.1332.15
11 pg
…establish
that Jane Doe 43’s claims should be barred because they are outside the ten (10) year statute of
limitation period and also that they somehow establish that Epstein is not within the New York
Court’s jurisdiction.
Accordingly…
giuffre-maxwell
gov.uscourts.nysd.447706.343.0
8 pg
…(S.D.N.Y. April 30, 1999), is perfectly illustrative:
This Court also recognizes that “service pursuant to the Hague Convention may be a
time-consuming process even in an English-speaking jurisdiction ....” . . . [t]he Court
therefore grants plaintiff additional…
giuffre-maxwell
gov.uscourts.nysd.447706.562.1
13 pg
…among other
things, calling Giuffre a liar in published statements with the malicious intent of discrediting and
further damaging Giuffre worldwide.
JURISDICTION AND VENUE
2. This is an action for damages in an amount in excess of the minimum
jurisdictional…
giuffre-maxwell
gov.uscourts.nysd.447706.962.0
7 pg
…07433-RWS Document 962 Filed 12/18/18 Page 3 of 7
ARGUMENT
I. The Court has jurisdiction to enforce its Protective Order as to materials held by
the parties, none of which is at issue in the appeals.
Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1351.0
32 pg
…in its unsealing review; and (6) declining to make public
certain pseudonymized third-parties’ submissions made in support of
continued sealing.
Defendant Maxwell argues that this court is without jurisdiction to
review the first of these arguments, which challenges the…
giuffre-maxwell
gov.uscourts.nysd.447706.1.0
12 pg
…among other
things, calling Giuffre a liar in published statements with the malicious intent of discrediting and
further damaging Giuffre worldwide.
JURISDICTION AND VENUE
2. This is an action for damages in an amount in excess of the minimum
jurisdictional…
giuffre-maxwell
gov.uscourts.nysd.447706.29.1
18 pg
…GD-15-18156). Plaintiff did not challenge
the removal. This Court has jurisdiction over this matter pursuant to 28 U.S.C. § 1332(a).
bñÜáÄáí=^=
Case
Case1:15-cv-07433-RWS
2:15-cv-01658-AJS Document
…
giuffre-maxwell
gov.uscourts.nysd.447706.24.1
13 pg
…among other
things, calling Giuffre a liar in published statements with the malicious intent of discrediting and
further damaging Giuffre worldwide.
JURISDICTION AND VENUE
2. This is an action for damages in an amount in excess of the minimum
jurisdictional…
giuffre-maxwell
gov.uscourts.nysd.447706.622.0
17 pg
…[email protected]
iii. A brief statement by each party as to the basis of subject matter jurisdiction
and a brief statement by each other party as to the presence or absence of
subject matter jurisdiction. Such a statement shall…
giuffre-maxwell
gov.uscourts.nysd.447706.54.0
11 pg
…THE ACTION1
1. Ms. Maxwell denies the factual allegations and legal conclusions contained in
Paragraph 1.
JURISDICTION AND VENUE
2. Paragraph 2 contains legal conclusions for which no response is required. To the
extent the Court determines a response is…
giuffre-maxwell
gov.uscourts.nysd.447706.961.0
9 pg
…the destruction or return of the
confidential materials she possesses.2
Further complicating the question is whether this Court even currently possesses
jurisdiction to order the return or destruction of documents implicated in ongoing appellate
proceedings before the Second Circuit…
giuffre-maxwell
gov.uscourts.nysd.447706.1349.0
31 pg
…in its unsealing review; and (6) declining to make public
certain pseudonymized third-parties’ submissions made in support of
continued sealing.
Defendant Maxwell argues that this court is without jurisdiction to
review the first of these arguments, which challenges the…
giuffre-maxwell
gov.uscourts.nysd.447706.931.0
15 pg
…at this time. We have asked for the
21 deposition in that case of Mr. Epstein in order to hit these
22 issues of statute of limitations and jurisdiction. They won't
23 agree to it.
24 So, we bend…
giuffre-maxwell
gov.uscourts.nysd.447706.40.0
8 pg
…and (j) any other person by written
agreement of the parties or by Order of a Court of competent jurisdiction.” Ms.
Giuffre made the proposed addition above because she contends it will alleviate
debate over a document that has been…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…heard, Dershowitz settled the underlying
litigation. Dershowitz has insisted upon keeping confidential the monetary settlement that
resolved the claims against him.23 The trial court declined to retain jurisdiction to hear Ms.
Giuffre’s sanctions claims after the settlement. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…trial is simply wrong. Plaintiff offers a single criminal case, United States v.
Amuso, which addressed the admissibility of evidence of physical flight from the jurisdiction as
proof of consciousness of guilt. 21 F.3d 1251, 1258 (2d Cir. 1994)…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…arguing that until
the punitive damages phase of this proceeding is reached the discovery is not relevant. Nonetheless,
public information suggests significant assets – and the possibility that she is transferring assets outside
the reach of the Court’s jurisdiction. See…
giuffre-maxwell
gov.uscourts.nysd.447706.41.5
18 pg
…Material; and
hi. any other persons by written agreement of the parties or by Order of a Court Formatted: Font: 12 pt
of competent jurisdiction.
6. Prior to disclosing any CONFIDENTIAL INFORMATION to any person
listed above (other than counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.33
24 pg
…Heaney, Donna Oliver P.A and Dr. Streeter – reside in Colorado. Because they are outside
of the jurisdiction, they are not subject to be compelled to appear at trial, requiring that their
depositions be taken to present their testimony.
Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.4
23 pg
…Material; and
hi. any other persons by written agreement of the parties or by Order of a Court Formatted: Font: 12 pt
of competent jurisdiction.
6. Prior to disclosing any CONFIDENTIAL INFORMATION to any person
listed above (other than counsel…