giuffre-maxwell
gov.uscourts.nysd.447706.492.0
9 pg
…Because Ms. Giuffre has shown the importance of reopening Defendant’s deposition on
these several important documents, because Defendant has not offered any substantial countervailing
consideration, the Court should allow Ms. Giuffre to question Defendant in a deposition about these…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…she was flown to the financier’s
vast Zorro Ranch after he offered to pay for her to attend a summer educational
programme in Thailand.
3/6
Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29…
giuffre-maxwell
gov.uscourts.nysd.447706.1248.0
6 pg
…Supp. 2d at 621–22. It does not appear that the Does have offered the
requisite “specific facts,” nor that closure is “essential to preserve higher values.” See Delta Air
Lines, 2020 WL 2614704, at *4.
Intervenors address the Does…
giuffre-maxwell
gov.uscourts.nysd.447706.1304.0
3 pg
…which “‘honor’ killings are a real risk,” and “instead concluding
[that] she . . . offered no more than generalized concerns of adverse publicity.” Doe 107 Br. at 2, 20.
(internal quotation marks omitted). We assume the parties’ familiarity with the underlying facts…
giuffre-maxwell
gov.uscourts.nysd.447706.1351.0
32 pg
…2) holding that the transcript of Giuffre’s
deposition in a separate action, offered by a third-party in support of a
motion to intervene in this case, was entitled to no more than a “barely
cognizable” presumption of public…
giuffre-maxwell
gov.uscourts.nysd.447706.749.0
9 pg
…Limine 4) ....... 9
5. Prince Andrew and Buckingham Palace’s denials of Plaintiff’s claims are not offered
for the truth of the matter asserted (Motion in Limine 5).............................................. 11
6. Evidence Regarding Plaintiff’s Sexual History and Reputation is…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…Additionally, Plaintiffs' counsel have identified
approximately four boxes of documents that they have offered to make available to Dershowitz's
counsel for inspection. vAs of today's date Plaintiffs have produced all documents which are
properly subject to discovery in…
giuffre-maxwell
gov.uscourts.nysd.447706.1303.0
3 pg
…which “‘honor’ killings are a real risk,” and “instead concluding
[that] she . . . offered no more than generalized concerns of adverse publicity.” Doe 107 Br. at 2, 20.
(internal quotation marks omitted). We assume the parties’ familiarity with the underlying facts…
giuffre-maxwell
gov.uscourts.nysd.447706.1349.0
31 pg
…2) holding that the transcript of Giuffre’s
deposition in a separate action, offered by a third-party in support of a
motion to intervene in this case, was entitled to no more than a “barely
cognizable” presumption of public…
giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…3, 2019). There, the proposed intervenors sought “materials (1) offered into evidence but
excluded by the Court at trial, (2) used to refresh a witness’s recollection, or (3) discussed on the
record but never moved into evidence.” Id. at…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…Counsel
for (4) Jeffrey Epstein, offered to accept service on or about April 11 but Plaintiff ignored that
offer for more than six weeks. Plaintiff only began on June 12 any attempt to schedule that
deposition in the Virgin Islands…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.1
8 pg
…at the hearing, commented on the content of the hearing. As reported by Bloomberg,
Mr. Boies offered his gratuitous critique of defense counsel, commented on the credibility of Ms.
Maxwell and his client, and commented on what Mr. Boies considers…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…the
20 fact that there was information in this book that Maxwell was
21 knowledgeable of at the time she made her defamatory statement.
22 So not offered for the truth of the fact that the number was
23 one…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…2019) (“documents merely shown to witnesses or otherwise
discussed in Court but not offered into evidence” do not constitute judicial documents because
“neither relevant to the performance of the judicial function nor useful in the judicial process”).
10
Case…
giuffre-maxwell
gov.uscourts.nysd.447706.66.0_1
35 pg
…which is next Friday.
3 We also offered to hold that deposition transcript confidential
4 until such time as the protective order could be issued so that
5 there is no barrier to us being able to take this deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.17
13 pg
…the Confidential Materials was
never filed with the Court. They have offered no reason why they have refused to return or
destroy Confidential Materials “and all copies thereof” in their possession, custody and control
that have not been filed with…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.12
35 pg
…a time -- did you ever
18 take a photography class in school?
19 A. Yes.
20 Q. And did there ever come a time when
21 Maxwell offered to buy you a camera?
22 A. Yes.
23 MS. MENNINGER: Objection…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…presumably, to the protective order. We had
17 previously offered defense counsel to sign the acknowledgment
18 of the protective order, which does provide for disclosure to
19 witnesses and witnesses' counsel. They didn't take us up on it…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…in
an adversarial process. Although affidavits and depositions are
offered “under penalty of perjury,” it is in fact exceedingly rare for
anyone to be prosecuted for perjury in a civil proceeding.45 Similarly,
44 In relevant part, Rule 11 provides…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.39
36 pg
…which is next Friday.
3 We also offered to hold that deposition transcript confidential
4 until such time as the protective order could be issued so that
5 there is no barrier to us being able to take this deposition…