giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…particularly in light of
Ms. Giuffre’s punitive damages claim as well as press reports suggesting that the Defendant may
be selling her assets in New York and transferring the money outside the jurisdiction.
Accordingly, Defendant’s motion for a…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…particularly in light of
Ms. Giuffre’s punitive damages claim as well as press reports suggesting that the Defendant may
be selling her assets in New York and transferring the money outside the jurisdiction.
Accordingly, Defendant’s motion for a…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.16
22 pg
…and upon information and belief as to all other
matters, as follows:
1. This cause of action arises under federal statutes and jurisdiction is
proper under 28 U.S.C. $ 1331.
2. Plaintiff files this Complaint under a pseudonym…
giuffre-maxwell
gov.uscourts.nysd.447706.363.6
15 pg
…3 voluntarily submits herself to this Court’s
jurisdiction.
Case 1:15-cv-07433-LAP Document 363-6 Filed 08/11/16 Page 3 of 15
result is that she’ll go to jail because she will repeat her…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.1
8 pg
…from prejudicial outside interferences. Neither prosecutors, counsel for defense,
the accused, witnesses, court staff nor enforcement officers coming under the jurisdiction of the
court should be permitted to frustrate its function.” Sheppard v. Maxwell, 384 U.S. 333, 363
(1966…
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.447706.562.1
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.447706.1.0
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.447706.54.0
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.447706.35.0
31 pg
…Notably, Maxwell does not cite to any New York case in
opposing this request, nor does she cite to a case from any other jurisdiction that is at all on point.
7
Giuffre. See Rule 37(e)(2)(b),(c)…
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.447706.1111.0
69 pg
…COMPLAINT
COMES NOW, the Government of the United States Virgin Islands ("Government"") and
files this First Amended Complaint against the above-named Defendants and in support thereof,
would show unto the Court as follows:
JURISDICTION AND PARTIES
1. The Attorney…
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.447706.1307.4
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.447706.1325.19
20 pg
…on your behalf, have initiated, since
January 1, 2015, identifying the jurisdiction, the date of initiation of the action, and the
subject matter of the action.
ANSWER:
Ms. Maxwell objects to this Interrogatory as vague and ambiguous, specifically by failing…
giuffre-maxwell
gov.uscourts.nysd.447706.406.0
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.447706.1330.15
43 pg
…LUCIE D INDIAN RIVER D OKEECHOBEE D HIGHLANDS
II. BASIS OF JURISDICTION (Place an "X" in One Rox Only) Ill. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X" in One Box/or Plaintiff}
…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…despite Ms. Giuffre’s unfortunate passing, there continued to be adversity as to all the issues
on appeal, allowing the Second Circuit to retain jurisdiction over all the parties’ arguments.
On remand, however, the same might not be true. Whether…