giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…to Documents Describing
Sexual Abuse. ......................................................................................................4
III. Doe 97’s Objection Is Insufficient. .......................................................................5
IV. Doe 107’s Objection Should Be …
giuffre-maxwell
gov.uscourts.nysd.447706.1237.0
20 pg
…2 of 20
TABLE OF CONTENTS
PRELIMINARY STATEMENT .................................................................................................1
ARGUMENT ..............................................................................................................................3
I.…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…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.447706.130.0
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.447706.1279.0
2 pg
…giving Doe 171 ample notice to decide on what she wanted
to do in the event the Court overruled her objection.
Doe 171 has had ample time to appeal in a non-urgent basis and she has not done so…
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.447706.1335.3
223 pg
…MCCAWLEY: I can make my record, and my
16 record is she's not going to be speaking with
17 respect to individuals' names that are named in
18 generalities in this document.
19 SPECIAL MASTER: Objection overruled. You
20…
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.447706.1328.4
40 pg
…2016).
Plaintiff objected to this interrogatory on the ground it requested pre-1999 medical
information in “violat[ion]” of the Court’s ruling. The objection should be overruled. The issue
4
Plaintiff’s voluminous arguments and argumentative citations to case…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.12
223 pg
…MCCAWLEY: I can make my record, and my
16 record is she's not going to be speaking with
17 respect to individuals' names that are named in
18 generalities in this document.
19 SPECIAL MASTER: Objection overruled. You
20…
giuffre-maxwell
gov.uscourts.nysd.447706.99.0
22 pg
…withholding any documents based on “copyright” and
“proprietary” objections. In fact, she did withhold those documents – until this
Court overruled her objection on March 17th. (Transcript at 13-17). She then
provided thousands of pages of supposedly “copyright protected” and…
giuffre-maxwell
gov.uscourts.nysd.447706.185.8
24 pg
…privilege in these circumstances would result in nothing more than the
concealment of the truth. Plaintiffs’ objections on the basis of the attorney-client privilege
should be overruled.
2. Plaintiffs Have Waived Their Right To Rely On The Work Product…
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.447706.354.0
40 pg
…2016).
Plaintiff objected to this interrogatory on the ground it requested pre-1999 medical
information in “violat[ion]” of the Court’s ruling. The objection should be overruled. The issue
4
Plaintiff’s voluminous arguments and argumentative citations to case…
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.447706.1218.36
2 pg
…Dershowitz Regarding Meetings with
David Boies" to Defendant Alan M. Dershowitz's Motion in Limine to Overrule Objections As to
Application of Settlement Rules, Filing # 35429605 E-Filed 12111/2015 at 10:08:04 a.m.
Having reviewed the record…
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.447706.1157.0_1
5 pg
…should . . . be unsealed if
and when the Court overrules Maxwell’s forthcoming objections”
for the next set of motions. (See Nov. 10 Letter at 2.)
Defendant contends otherwise, reasoning that failure to file an
Objection does not result in the…