giuffre-maxwell
gov.uscourts.nysd.447706.1237.0
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…2 of 20
TABLE OF CONTENTS
PRELIMINARY STATEMENT .................................................................................................1
ARGUMENT ..............................................................................................................................3
I.…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
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…Maxwell objected to the second deposition, based in part on her privacy
concerns about testifying to her adult consensual activity (id.);
• Judge Sweet overruled Ms. Maxwell’s objections to the deposition, ruling that her
“privacy concerns are alleviated by the…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…2016 that Ms. Maxwell must sit for a second deposition on
eight topics all “relating to [her] own sexual activity” and “her knowledge of the sexual activity
of others.” (DE 316-6 at 10) Judge Sweet overruled Ms. Maxwell’s…
giuffre-maxwell
gov.uscourts.nysd.447706.130.0
5 pg
…a non-existent “investigative
privilege.” When Ms. Maxwell demonstrated that the “investigative privilege” does not exist,
Plaintiff threw up the inapplicable “public interest” privilege, the assertion of which was
overruled by your Honor on April 21, 2016. The Court ordered:
…
giuffre-maxwell
gov.uscourts.nysd.447706.148.0
9 pg
…When Ms. Maxwell demonstrated that the “investigative privilege” did not exist,
Plaintiff threw up the inapplicable “public interest” privilege, the assertion of which was
overruled by the Court on April 21, 2016.
The Court Ordered:
“The criminal investigation. Any materials…
giuffre-maxwell
gov.uscourts.nysd.447706.66.0_1
35 pg
…of this
20 production on -- you are going to have to -- well, wait a
21 minute. Let me put it this way. The objections to this 16 are
22 overruled except for the privilege. OK?
23 MS. MENNINGER: Your Honor…
giuffre-maxwell
gov.uscourts.nysd.447706.1062.0
7 pg
…85.
B. Dershowitz’s Present, Expanded Second (or Third) Bite at the Apple and
Giuffre’s Acquiescence to the Same
With his objections to the protocol overruled in Maxwell, and having already failed to
circumvent it once in Dershowitz, Dershowitz…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.39
36 pg
…of this
20 production on -- you are going to have to -- well, wait a
21 minute. Let me put it this way. The objections to this 16 are
22 overruled except for the privilege. OK?
23 MS. MENNINGER: Your Honor…
giuffre-maxwell
gov.uscourts.nysd.447706.1253.0
12 pg
…1247 at 20, Plaintiff only addresses Does
28, 97 and 144’s replies. The Court should overrule their objections.1 In its April 19, 2022, ruling
concerning the first set of Non-Party Objectors, the Court ordered that certain documents…
giuffre-maxwell
gov.uscourts.nysd.447706.57.1
26 pg
…and Ogden v. London Electric Railway Co.
. (1933) 49 T.L.R. 542, C.A. overruled.
Anderson v. Bank of British Columbia (1876) 2 Ch.D. 644,
Sir George Jessel M.R. and C.A. and Grant v. Downs (1976…
giuffre-maxwell
gov.uscourts.nysd.447706.1312.0
9 pg
…testify under pseudonym because “these generalized
concerns are present in every high-profile criminal case”).
Accordingly, the Court should overrule the objections of Doe 133 and unseal the judicial
documents pertaining to them.
1
By order dated July 20, 2023…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.0
35 pg
…s objections should suffice.
14
Case 1:15-cv-07433-LAP Document 1156 Filed 11/19/20 Page 19 of 19
CONCLUSION
For the foregoing reasons, the Court should overrule Maxwell’s objections as to Docket
Entries 231, 279…
giuffre-maxwell
gov.uscourts.nysd.447706.1213.0
18 pg
…be unsealed now will reduce the need to revisit documents already partially unsealed and
will streamline the unsealing process (likely by years).
CONCLUSION
For the foregoing reasons, the Court should overrule Maxwell’s objections as to Docket
Entries 345, 356…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.37
9 pg
…sanctions against Defendant, Alan M. Dershowitz in connection to his filing the
Motion in Limine to Overrrule Objections As to Application of Settlement Rules, Filing#
35429605 E-filed 12/11 /2015 at 10:08:04 a.m., and to strike…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.13
22 pg
…seizure—within the meaning of the fourth
amendment.” Boyd v United States, 116 U.S. 616, 634–35 (1886), overruling in part on other
grounds as recognized in Fisher v. United States, 425 U.S. 391, 407–08 (1976).
Finally…