giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…Maxwell does not interpose objections to unsealing, subject to Non-
Parties’ opportunity for notice to be heard. That the process for review of literally thousands of
pages of sealed materials takes time to accomplish is not a reason to unseal…
giuffre-maxwell
gov.uscourts.nysd.447706.66.0_1
35 pg
…imposed upon you. I'm sorry
3 about the inconvenience that you have imposed upon me.
4 But having said all of that, this really is the first
5 time that we've had an opportunity, I think, to get…
giuffre-maxwell
gov.uscourts.nysd.447706.1135.0_6
1 pg
…Maxwell believes that her proposed additional redactions comport
with the Court’s direction that Non-Parties be given the opportunity to review and object
before any information identifying their identity or any conduct attributed to them (including
as either an…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.39
36 pg
…imposed upon you. I'm sorry
3 about the inconvenience that you have imposed upon me.
4 But having said all of that, this really is the first
5 time that we've had an opportunity, I think, to get…
giuffre-maxwell
gov.uscourts.nysd.447706.1097.0_1
6 pg
…will (1) undermine the careful unsealing process
agreed to by the parties in Maxwell, and (2) infringe on the
privacy or other countervailing interests against disclosure of
the Does without their having notice and an opportunity to be
heard. Accordingly…
giuffre-maxwell
gov.uscourts.nysd.447706.637.0
12 pg
…Generally, the work product privilege is waived when protected materials
are disclosed in a manner which is either inconsistent with maintaining secrecy against
opponents or substantially increases the opportunity for a potential adversary to obtain the
protected information.” Id. at…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.18
8 pg
…PAGLIUCA: If you can just do a little
20 pause in between his question and your answer.
21 I need an opportunity to object to any form or
22 foundation problem with his question.
23 THE WITNESS: Sure.
24 MR…
giuffre-maxwell
gov.uscourts.nysd.447706.492.0
9 pg
…documents are highly relevant. Whatever Defendant argues about
her prior deposition, she cannot claim that she was questioned about Ms. Giuffre
deserves the opportunity to ask Defendant about them.
II. ARGUMENT
A. Discovery Concerning is Not Duplicative, and it is…
giuffre-maxwell
gov.uscourts.nysd.447706.610.0
3 pg
…assumed to have supported their papers with admissible
evidence”). “If the rationale behind access is to allow the public an opportunity to assess the
correctness of the judge’s decision, documents that the judge should have considered or relied
1…
giuffre-maxwell
gov.uscourts.nysd.447706.686.0
17 pg
…Trafficking
Organization Is Also Admissible Under Rule 404(b) to Show Motive and
Plan. .........................................................................................................................7
C. Evidence of Defendant’s Involvement in Epstein’s Sex Trafficking
…
giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…See Amodeo, 71 F.3d at 1051 (“Similarly, a
court may consider whether the nature of the materials is such that there is a fair opportunity for
the subject to respond to any accusations contained therein.”). Accordingly, Doe 144’s…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…rendition of legal services to the client). Some Florida courts have even
recognized serious due process issues could be created by a procedure through which a client lost
their privilege without an opportunity to be heard in the proceedings. See…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.1
8 pg
…able to
perpetrate so many crimes against young females.
These comments violate subsections (6) and (7) of the Rule.
It appears that given any opportunity lawyers associated with the prosecution of this case
will offer any opinion that damages Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…. have reason to
believe that you have personally observed Jeffrey Epstein in the presence of underage females,
and we would like the opportunity to question you under oath about those observations.” Id at
SCAROLA 016567. I replied that “If you…
giuffre-maxwell
gov.uscourts.nysd.447706.1254.0
18 pg
…asserted privacy interests that they
14 contend weigh against unsealing. These objecting Does have
15 been afforded the opportunity to respond to the written
16 positions of the parties and the Herald and some, but not all
17 of them…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…above is in the possession
of Defendant’s agent, who caused the false statements to be issued to various media outlets. Ms.
Giuffre has not had the opportunity to depose Maxwell’s agent Ross Gow; therefore, this answer
remains incomplete…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…the record in the CVRA Action, these allegations were
not sealed; instead, they were filed publicly without any evidence to support them and without
affording Professor Dershowitz an opportunity to dispute them. Id. Although Ms. Giuffre
elaborated these false allegations…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…McCAWLEY: Your Honor, if I could, I'd like the
8 opportunity -- because there are only a few of the witnesses
9 that fall into this category --
10 THE COURT: Okay. That's one thing. Let's sort of
11…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…of the allegations posited by reporter Vicky Ward.
Plaintiff is not permitted to re-depose Ms. Maxwell on issues already covered, or which
she had the opportunity to cover, in the first 7-hour deposition, particularly in light of the
…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…finally broke down.
She began moving uneasily in her chair as the judge said the evidence against her was
‘strong’.
When Judge Nathan said a ‘combination of factors’ showed she had the ‘motive and
opportunity’ to flee before her trial…