giuffre-maxwell
gov.uscourts.nysd.447706.1330.23
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.447706.730.0
14 pg
…BACKGROUND .............................................................................................. 1
III. DISCUSSION ...................................................................................................................... 2
A. Ms. Giuffre’s FBI 302 is Offered to Prove That She Reported Her Alleg…
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.447706.185.7
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.447706.1155.0_2
13 pg
…and submit this response based on the known
portions of the documents as well as the parties’ public representations as to their contents.
Intervenors incorporate by reference their arguments offered in response to the alleged
“Countervailing Interests” identified by Ms…
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.447706.1328.20
14 pg
…offered to have sex with
him in exchange for not telling her parents she had failed to go to school that day.
Both Plaintiff and her 17-year old boyfriend verified they had had sexual
intercourse in the days before…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.30
40 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.447706.824.0_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.447706.1257.22
40 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.447706.1073.0
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.447706.1296.12
29 pg
…soon as that in-person meeting
was accomplished in early January, Ms. Giuffre filed the appropriate papers with this Court and
immediately offered to make Ms. Ransome available to Defendant for a deposition. After first
delaying in taking that deposition…
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.447706.1296.9
29 pg
…soon as that in-person meeting
was accomplished in early January, Ms. Giuffre filed the appropriate papers with this Court and
immediately offered to make Ms. Ransome available to Defendant for a deposition. After first
delaying in taking that deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.0
35 pg
…the proposition that
a trial court can violate a defendant’s due process rights when it fails to take precautions against
the dissemination to jurors of evidence made available to the media that was never offered at trial.
Maxwell Br…