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.447706.1213.1
10 pg
…unsealing has not yet expired.
to Improper Objection
344 Already public.
346 Unseal in full. Note: Original parties agree.
346-1 Unseal in full. Note: Original parties agree.
Unseal and redact only names and identifying …
giuffre-maxwell
gov.uscourts.nysd.447706.1090.36_1
35 pg
…of . The
process may take some time but it is the appropriate method for you to obtain any possible records
regarding your recovery. Hope this helps.
Best wishes,
Jason
-----Original Message-----
From:
Sent: Wednesday, August 27, 2014 9:49 AM…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…as
news, as they are defamatory.”
Churcher is the sole source of information regarding the original story told by Plaintiff,
and was the author of the first articles publishing Plaintiff’s claims. She was actively and
personally involved in changing…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.26
4 pg
…``If a great network thinks it’s increasing its credibility by hiring a
convicted perjurer to tell us the truth, something’s wrong.’’
© 2015 Thomson Reuters. No claim to original U.S. Government Works. 1
Case 1:15…
giuffre-maxwell
gov.uscourts.nysd.447706.1099.0
4 pg
…requested Excerpts (and who therefore do not intend to object to
unsealing) will also be exceedingly helpful to the Original Parties tasked with redacting the names
of Non-Parties who have not yet had the opportunity to object to unsealing…
giuffre-maxwell
gov.uscourts.nysd.447706.1167.2
27 pg
…unsealing has not yet
232-8 6.20.16 on Protective Order; potential
C1-2 expired.
C1-3 Note: The Original Parties sent
witness in criminal trial …
giuffre-maxwell
gov.uscourts.nysd.447706.1327.12
11 pg
…privileged document has been
identified. Ms. Maxwell’s original search for responsive documents was complete at the time it
was conducted in February 2016. The recent forensic imaging and searches have merely
confirmed as much. Plaintiff has sent defense counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.1289.0
3 pg
…motion for
reconsideration “shall be served withing fourteen (14) days after the entry of the Court’s
determination of the original motion” and “shall” include “a memorandum setting forth concisely
the matters or controlling decisions which counsel believes the Court…
giuffre-maxwell
gov.uscourts.nysd.447706.110.0
7 pg
…1
In deciding Ms. Maxwell’s Motion to Stay Discovery (Doc # 18), this Court agreed with
Plaintiff’s original contention, stating “this case involves a single claim against a single
defendant, relating to an ongoing series of events in which…
giuffre-maxwell
gov.uscourts.nysd.447706.1087.0
4 pg
…July 29,” (dkt. no. 1083 at 1),
Ms. Giuffre at a minimum gave the Court time to conduct a review
of her proposed redactions while preserving the original schedule
for unsealing. By contrast, Ms. Maxwell at 2:00 p.m…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.7
11 pg
…7 impact or their right or anybody else's right to
8 go back to Judge Lynch and ask for more time from
9 this witness based upon my ruling or my reading of
10 the original order.
11 MS…
giuffre-maxwell
gov.uscourts.nysd.447706.24.3
3 pg
…said she would not be commenting and
referred journalists to a 2011 statement in which she said the allegations against her were “abhorrent”.
Ghislaine Maxwell’s original response to the lies and defamatory claims remains the same
Ross Gow
However…
giuffre-maxwell
gov.uscourts.nysd.447706.1079.0
4 pg
…close of
briefing, (id.), 1 this is plowed ground. Indeed, in her original
objection to unsealing, Ms. Maxwell argued that the specter of
ongoing criminal investigations into unknown individuals
associated with Jeffrey Epstein--a group that, of course, includes
Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.4
35 pg
…The
process may take some time but it is the appropriate method for you to obtain any possible records
regarding your recovery. Hope this helps.
Best wishes,
Jason
-----Original Message-----
From: Robert Giuffre Jane Doe 2
Sent: Wednesday, August 27…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.8
10 pg
…On June 20, 2016, this
Court granted Ms. Giuffre’s Motion and directed Defendant to sit for a second deposition to
answer the questions she originally failed to answer. (June 20, 2016 Sealed Order, filed in
redacted version DE 264…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.39
35 pg
…process may take some time but it is the appropriate method for you to obtain any possible records
regarding your recovery. Hope this helps.
Best wishes,
Jason
-----Original Message-----
From: Robert Giuffre [mailto:[email protected]]
Sent: Wednesday, August 27…
giuffre-maxwell
gov.uscourts.nysd.447706.1167.0
31 pg
…320, & 335. Ms. Maxwell amended her
original chart to, inter alia, include Plaintiff’s position, to correct some entries wherein the
Case 1:15-cv-07433-LAP Document 1167 Filed 12/01/20 Page 2 of 3
Second Circuit…
giuffre-maxwell
1320-39
35 pg
…process may take some time but it is the appropriate method for you to obtain any possible records
regarding your recovery. Hope this helps.
Best wishes,
Jason
-----Original Message-----
From: Robert Giuffre [mailto:[email protected]]
Sent: Wednesday, August 27…
giuffre-maxwell
gov.uscourts.nysd.447706.26.1
26 pg
…
[6]
plaintiffs pled plausible claim that defendant was [4]
directly liable for alleged defamation; and Libel and Slander
By others in general
© 2016 Thomson Reuters. No claim to original U.S. Government Works. …