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.447706.1226.0
4 pg
…for Unsealing Decided Motions. See DE 1224.
We write to express our views regarding the parties’ respective submissions, as well as that
offered by the Miami Herald. See DE 1225.
As directed by the Second Circuit, this Court has made…
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.447706.1090.46
14 pg
…That conferral
was held on May 9 and May 10. Mr. Edwards offered, for example, to consider whether a verified representation by
Plaintiff all of the statements that the media “got wrong” would suffice instead of a re-opened deposition…
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.447706.599.0
12 pg
…Ms. Giuffre has correctly explained why Taylor should not be
allowed to opine on
The remaining opinions offered by Taylor would not be relevant or helpful to the jury,
which is why Taylor should be precluded from testifying at all…
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.447706.1325.15
14 pg
…That conferral
was held on May 9 and May 10. Mr. Edwards offered, for example, to consider whether a verified representation by
Plaintiff all of the statements that the media “got wrong” would suffice instead of a re-opened deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.602.0
11 pg
…of Dr. Phillip W. Esplin (hereinafter
“Esplin”).
PRELIMINARY STATEMENT
Ms. Giuffre has moved to exclude three opinions offered by Defendant’s expert Esplin,
specifically any opinions regarding
See McCawley Dec. at Exhibit 1, Defendant has already
c…
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.447706.535.0
18 pg
…VI. TAYLOR SHOULD BE PRECLUDED FROM OFFERING ANY
OPINIONS REGARDING ............................................ 9
TAYLOR SHOULD BE PRECLUDED FROM OFFERING
ANY OPINIONS REGARDING
.....................…
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.447706.1155.0_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.447706.1204.0
3 pg
…Raddatz, 447 U.S. 667, 677 (1980) (due process guarantees an
accused the right to challenge the admissibility of evidence offered against her). If the
government’s conduct was unlawful and unconstitutional, as Ms. Maxwell contends it was,
Judge Nathan…
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.447706.1078.1
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…