giuffre-maxwell
gov.uscourts.nysd.447706.1015.0
4 pg
…A. Preska
District Court Judge
United States District Court for the
Southern District of New York
500 Pearl Street
New York, NY 10007
Re: MOTION TO DOCKET AND UNSEAL MAXWELL’S DECEMBER 5, 2019,
LETTER
Giuffre v. Maxwell, Case No…
giuffre-maxwell
gov.uscourts.nysd.447706.1042.0
2 pg
…1037, 1038 , 140
Giuffre v. Maxwell, Case No. 15-cv-7433-LAP
Dear Judge Preska:
Intervenors Julie Brown and Miami Herald Media Company write in response to the
parties’ letters dated March 26, 2020 (Dkt. Nos. 1037, 1038), and in…
giuffre-maxwell
gov.uscourts.nysd.447706.1029.0
2 pg
…New York, NY 10007
Re: Giuffre v. Maxwell,
Case No. 15-cv-7433-LAP
Dear Judge Preska:
Plaintiff Virginia Giuffre writes in response to several positions that Defendant advances
in her February 4, 2020 letter. Dkt. 1028. First, this Court…
giuffre-maxwell
gov.uscourts.nysd.447706.1321.0
2 pg
…The Honorable Loretta A. Preska
District Court Judge
United States District Court for the
Southern District of New York
500 Pearl Street
New York, NY 10007
Re: LETTER MOTION TO UNSEAL DOCKET ENTRY 1026-3
Giuffre v. Maxwell, Case No…
giuffre-maxwell
gov.uscourts.nysd.447706.829.0
4 pg
…United States District Court for the Southern District of New York
500 Pearl Street
New York, NY 10007
Via ECF
Re: Plaintiff’s Letter Motion to Redact the Transcript of the Summary-
Judgment Hearing on February 16, 2017
Giuffre v…
giuffre-maxwell
gov.uscourts.nysd.447706.542.3
2 pg
…These allegations
are all entirely
false.
It is unacceptable that letters sent by Ms Maxwell's legal
representatives to certain newspapers pointing out the truth
and asking for
the allegations to be withdrawn have simply been ignored.
In the circumstances…
giuffre-maxwell
gov.uscourts.nysd.447706.24.2
2 pg
…entirely false. Journalists and Bloggers
It is unacceptable that letters sent by Ms Maxwell's legal representatives to certain newspapers pointing out the truth and asking
for the allegations to be withdrawn have simply been ignored.
In the circumstances, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1050.0
12 pg
…please, when you
2 speak to say your name first so that the court reporter is able
3 to do a good transcript.
4 We have looked at your various letters regarding the
5 protocol, and with respect to paragraph…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…standing order regarding conferral on all discovery
issues prior to Motions practice, the sum total of Plaintiff’s stated conferral attempt is a footnote
stating that a letter was sent on September 23, 2016 “inquiring about the undisclosed account” –
a…
giuffre-maxwell
gov.uscourts.nysd.447706.443.0
4 pg
…4
address.
On August 3, 2016, Ms. Giuffre applied to this Court for a Letter Rogatory in order to
initiate a separate action in the United Kingdom to compel Mr. Gow to comply with the
subpoena. On August 11, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1254.0
18 pg
…by Ms. Maxwell in her letter stating that she
8 takes no position.
9 The Court has also considered the submission from
10 intervenors Julie Brown and Miami Herald Media Company.
11 Perhaps most importantly for our purposes today, the…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.23
9 pg
…Ms. Giuffre’s efforts included service
through The Hague Convention (twice), hiring an English firm to attempt personal service (Gow left
the country); and initiating a separate action in England pursuant to this Court’s Letter Rogatory. For
Epstein, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.15.0
29 pg
…denies the various allegations about her that have appeared
recently in the media. These allegations are all entirely false.
It is unacceptable that letters sent by Ms. Maxwell’s legal representatives to
certain newspapers pointing out the truth and asking…
giuffre-maxwell
gov.uscourts.nysd.447706.833.0
4 pg
…time & travel records, victim notification letters,
and a black book. This reference to evidence is otherwise discussed in publicly available articles
and even the public docket entries in this case.
2
Case 1:15-cv-07433-LAP Document 833…