giuffre-maxwell
gov.uscourts.nysd.447706.1046.0
3 pg
…the March 31, 2020 telephone
conference, to identify the first five motions for the unsealing process. The Original Parties have
met and conferred multiple times to propose five motions pertaining to J. Doe 1 and J. Doe 2, as
identified…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.2
70 pg
…What do you think? See you then ...
Take care,
Jenna
-----Original Messag e----
From: Sharon [email protected]
Sent: Monday, 7 March 2011 6:22 PM
To : Virginia Giuffre
Page 1 of 69 GIUff RE00372 0
…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…specifically filed in the CVRA case
to oppose his efforts to intervene in that case and was unquestionably already in his possession.
Plaintiffs subsequently delivered a Bates stamped version of their original July 2015
document production to Dershowitz's counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…The Careerist
April 11, 2016
Note: Since the original publication of this post, we've included additional statements by Alan
Dershowitz about the circumstances under which he's prepared to waive confidential
information.
It's not over.
If you thought…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.29
5 pg
…this deposition. 9 people who work at the house.
10 And I'm just going to state on the record that 1o BY MS. EZELL:
11 I wilJ keep that original. We will not attach it 11 Q. I understand…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.34
10 pg
…for you and will pass them by Jef1rey...l will also let
Finance him know abcut the modeling potentials!
Pumla Griszell
> Folders
> Recent
Lesley Groff
Executive Assistant to Jeffrey Epstein
---…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.42
5 pg
…this deposition. 9 people who work at the house.
10 And I'm just going to state on the record that 1O BY MS. EZELL:
11 I will keep that original. We will not attach it 11 Q. I understand…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.21
19 pg
…Filed 01/05/24 Page 8 of 19
Date: 4/25/16 ROYAL PALM BEACH POLICE DEPARTMENT Page: 6
Time: 8:52:07 Offense Report Program: CMS301L
1-97-002687 (Continued)
***************** *~*********NARRA TIVE # l ***************************
…
giuffre-maxwell
gov.uscourts.nysd.447706.562.1
13 pg
…2015, statement incorporated by reference “Ghislaine
Maxwell’s original response to the lies and defamatory claims remains the same,” an earlier
statement that had falsely described Giuffre’s factual assertions as “entirely false” and “entirely
untrue.”
32. Maxwell made the…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…a court would go about
determining that someone's reputation had already been ‘irreparably’ damaged—i.e., that no new
reader could be reached by the freshest libel” (Scalia, J.) (emphasis in original)), vacated on
other grounds, 477 U.S…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…permissive intervention allowed
only where “a claim or defense and the main action have a question of law or fact in common
and the intervention will not unduly prejudice or delay the adjudication of the rights of the
original parties.”)…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.7
30 pg
…Dr. Joseph Heaney, 6 and
Donna Oliver P.A.” (Mtn. at 4, emphasis original).
Defendant is trying to make it seem as if Ms. Giuffre deliberately hid the names of
treating physicians in the Emergency Room. As stated above, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.20.0
26 pg
…163,
179 (2d Cir. 2000) (“a writing which tends to disparage a person in the way of his office,
profession or trade is defamatory per se and does not require proof of special damages.”)
(Emphasis original, quotations and citations omitted…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…Brown, 929 F.3d at 49 (If a court “determines that documents filed by a
party are not relevant to the performance of a judicial function, no presumption of public access
attaches.”) (emphasis in original); see also United States v…
giuffre-maxwell
gov.uscourts.nysd.447706.1.0
12 pg
…2015, statement incorporated by reference “Ghislaine
Maxwell’s original response to the lies and defamatory claims remains the same,” an earlier
statement that had falsely described Giuffre’s factual assertions as “entirely false” and “entirely
untrue.”
32. Maxwell made the…
giuffre-maxwell
gov.uscourts.nysd.447706.24.1
13 pg
…2015, statement incorporated by reference “Ghislaine
Maxwell’s original response to the lies and defamatory claims remains the same,” an earlier
statement that had falsely described Giuffre’s factual assertions as “entirely false” and “entirely
untrue.”
32. Maxwell made the…
giuffre-maxwell
gov.uscourts.nysd.447706.755.0
75 pg
…13 into the substance of that argument, but a reply was submitted
14 again on Tuesday night in that case that was more than twice as
15 long as the original motion and contained entirely new
16 arguments, new documents…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.14
30 pg
…Dr. Joseph Heaney,7 and
Donna Oliver P.A.” (Mtn. at 4, emphasis original).
Defendant is trying to make it seem as if Ms. Giuffre deliberately hid the names of
treating physicians in the Emergency Room. As stated above, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.561.0
22 pg
…stated, ‘[t]he deposition has always been, and still is, treated as a substitute, a
second-best, not to be used when the original is at hand.’” United States v. Int’l Bus. Machines
Corp., 90 F.R.D. 377…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.6_3
17 pg
…When worked for
11 Jeffrey Epstein, did she perform massages?
12 A. I've testified that when
13 came originally, she came to answer
14 telephones. I believe at some point she
15 became a masseuse. I don ' t recollect…
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