giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…The Court Should Unseal Portions of Docket Entries the Second Circuit Already
Released. .................................................................................................................................... 6
III. The Court Should Unseal Portions of Documents Mentioning Doe 1 and Doe 2. ... 6
IV. …
giuffre-maxwell
gov.uscourts.nysd.447706.1331.32
4 pg
…the same freely and vo/untarif;· for the uses and purposes
therein mentioned.
[SEAL]
offtera/ seal the d.iy and year 1asl above written.
Hsiao-Chi…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.42
9 pg
…Clinton, Attorney General Eric Holder are expected to pay their respects. You
know, Chris mentioned to us, our NEW DAY family, that his father's life has served as
a lesson for him since he was a very little boy…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.12
15 pg
…Okay. Do you know how long --
19 A She -- I believe she mentioned that it was
20 some kind of -- mentioned something about being a
21 famous sexual abuse something.
22 Q You haven't read any of the reports…
giuffre-maxwell
gov.uscourts.nysd.447706.55.21
69 pg
…Q. Did you have any other duties other than 21 his estate, and what was my salary potentials, we
22 what you've mentioned? 22 discuss the time he was going to be in the Island,
23 A. Driving. Well…
giuffre-maxwell
gov.uscourts.nysd.447706.903.0
46 pg
…Epstein,
10 who has agreed to be liable under his deal, in which
11 Ms. Maxwell is not mentioned, by the way -- her name did not
12 appear in this nonprosecution agreement -- shows up, I don't
13 know why…
giuffre-maxwell
gov.uscourts.nysd.447706.26.1
26 pg
…but she hasn’t mentioned either her 3 ½ these new women who just came forward for the first
year incarceration or her extensive criminal record with time now ever asserted a legal claim back at the time
charges spanning…
giuffre-maxwell
gov.uscourts.nysd.447706.1290.0
3 pg
…s book, Perversion of Justice, contains allegedly
defamatory statements about Doe 171 and her alleged association with Jeffrey Epstein.” This
Court’s ruling also highlighted that Doe 171 was mentioned by name in Ms. Maxwell’s criminal
trial, directly connecting…
giuffre-maxwell
gov.uscourts.nysd.447706.561.0
22 pg
…Defendant’s participation in procuring girls and young women as part of Epstein’s sex
trafficking enterprise. Indeed, the Defendant is not even mentioned in that Florida complaint, as
the Court can determine with a quick word search. McCawley Dec…
giuffre-maxwell
gov.uscourts.nysd.447706.57.1
26 pg
…Such reports
and the statements of witnesses to such accidents are made for the
purposes mentioned in paragraphs 3 and 6 of this affidavit and equally
for the purpose of being submitted to the board's solicitor as material
upon…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…given the media attention focused on this case, and Plaintiff’s apparent
willingness to publicly disclose confidential information, not to mention Plaintiff’s counsels’
undisclosed communications with the media, Ms. Maxwell rightfully remains skeptical of
Plaintiff’s ability to abide…
giuffre-maxwell
gov.uscourts.nysd.447706.343.0
8 pg
…standard.”)
Defendant cites various cases, but not a single opinion is relevant here. Not a single one of
Defendant’s cases mention service under The Hague Convention, or service abroad, or procuring
service through an action in a foreign court…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.4
40 pg
…such an interrogatory
is merely for the purpose of imposing a burden on Ms. Giuffre and her attorneys,
not to mention the purposes of harassment.
Pursuant to the Rules, if requested documents are not yielded in a “reasonable
inquiry,” Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.222.0
10 pg
…Plaintiff’s
Joinder Motion, ordered the portions of the Joinder Motion pertaining to non-parties such as Ms.
Maxwell stricken as ‘immaterial and impertinent,’ and restricted the documents mentioning those
‘lurid details’ from public access.” Id. at 4-5 (citations…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.10
64 pg
… Well, the test on
pertinence, I don't believe that the plaintiff is contesting
18
19
-- this but I will just mention it quickly, which is that in the
Flomenhaft case, the appellate court said that the test on
20…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.20
7 pg
…Order of April 15, 2016, not to mention
Plaintiff has never issued a discovery request for communications with witness .
And Ms. Maxwell has only used her ” account as a spam account since the mid-
2000’s, when she opened her…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.11
13 pg
…1219-11 Filed 07/15/21 Page 9 of 13
Case 1:15-cv-07433-LAP Document 1219-11 Filed 07/15/21 Page 10 of 13
Defendant fails to mention that a forensic review would not give Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.15.0
29 pg
…District Court Judge Marra denied
Plaintiff’s Joinder Motion, ordered the portions of the Joinder Motion pertaining to non-parties
2
Although the Complaint does not explicitly mention the 2011 Statement, it appears Plaintiff believes it to
be the “additional…
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