giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…only Doe 1 and Doe 2 have received notice of potential sealing thus far, and because the first five
motions contain the names of various other Non-Parties, Maxwell contends in her objection that
the Court cannot unseal any of…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…2016,
Order.
A. Defendant’s Refusal to Even Run Ms. Giuffre’s Name as a Search
Term.
Defendant has been recalcitrant in running even the most basic searches of electronic
data. For example, in a letter sent on June 8…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…(June 1, 2016) (McCawley Decl. at Sealed Exhibit 1).
Accordingly, mindspring was a domain name set up for Jeffrey Epstein and his household to
communicate with one another, and was, in fact, used in this manner.
The sworn testimony of…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…2016,
Order.
A. Defendant’s Refusal to Even Run Ms. Giuffre’s Name as a Search
Term.
Defendant has been recalcitrant in running even the most basic searches of electronic
data. For example, in a letter sent on June 8…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.2_1
10 pg
…Defendant simply cannot put forth valid objections to Ms.
Giuffre’s proposed terms.
Many of Ms. Giuffre’s proposed search terms are derived from the names listed in
Defendant’s Rule 26 disclosures and Plaintiff’s Rule 26 disclosures, who…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.33
24 pg
…As to both, Ms. Maxwell provided releases for Plaintiff’s signature.
On March 16, 2016, Plaintiff refused to provide the names of any of Plaintiff’s treating
physicians, nor the requested releases, claiming “privilege.” Menninger Decl., Ex. A.
On March…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…2016,
-
Order.
A. Defendant’s Refusal to Even Run Ms. Giuffre’s Name as a Search
Term.
Defendant has been recalcitrant in running even the most basic searches of electronic
data. For example, in a letter sent on June 8…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.1_2
24 pg
…As to both, Ms. Maxwell provided releases for Plaintiff’s signature.
On March 16, 2016, Plaintiff refused to provide the names of any of Plaintiff’s treating
physicians, nor the requested releases, claiming “privilege.” Menninger Decl., Ex. A.
On March…
giuffre-maxwell
1320-33
24 pg
…As to both, Ms. Maxwell provided releases for Plaintiff’s signature.
On March 16, 2016, Plaintiff refused to provide the names of any of Plaintiff’s treating
physicians, nor the requested releases, claiming “privilege.” Menninger Decl., Ex. A.
On March…
giuffre-maxwell
gov.uscourts.nysd.447706.231.0
23 pg
…As to both, Ms. Maxwell provided releases for Plaintiff’s signature.
On March 16, 2016, Plaintiff refused to provide the names of any of Plaintiff’s treating
physicians, nor the requested releases, claiming “privilege.” Menninger Decl., Ex. A.
On March…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…information
related to Epstein’s criminal enterprise in the Virgin Islands and beyond, and will be invaluable
for its CICO law enforcement action against the Estate and other named parties.1
LEGAL ARGUMENT
A. The USVI’s Motion to Intervene…
giuffre-maxwell
gov.uscourts.nysd.447706.561.0
22 pg
…spanning some 457 pages of testimony, Maxwell’s name is only mentioned a handful to
times, and there was no effort in any of those times to pin down what Dershowitz knew about
Maxwell’s involvement in Epstein’s sex…
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