giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…business, plane or automobile other vehicle owned or
controlled by Jeffrey Epstein.
RESPONSE:
In addition to the Preliminary Statement and General Objections, Ransome objects to this
request in that she is a non-party and this requests seeks an unlimited…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…business, plane or automobile other vehicle owned or
controlled by Jeffrey Epstein.
RESPONSE:
In addition to the Preliminary Statement and General Objections, Ransome objects to this
request in that she is a non-party and this requests seeks an unlimited…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…business, plane or automobile other vehicle owned or
controlled by Jeffrey Epstein.
RESPONSE:
In addition to the Preliminary Statement and General Objections, Ransome objects to this
request in that she is a non-party and this requests seeks an unlimited…
giuffre-maxwell
gov.uscourts.nysd.447706.22.0
14 pg
…examples include:
All documents identifying passengers, manifests, or flight plans for any helicopter
or plane ever owned or controlled by your or Jeffrey Epstein or any associated
entity from 1999 – present. (No. 9)
All documents relating to payments…
giuffre-maxwell
gov.uscourts.nysd.447706.851.0
158 pg
…which have also been produced
18 in this case, which place Ms. Giuffre on 23 flights with
19 defendant aboard Jeffrey Epstein's private plane.
20 So as these records actually show truancy, failed
21 grades, failure to complete courses…
giuffre-maxwell
gov.uscourts.nysd.447706.96.0
15 pg
…8, message pads. Defendant was intimately involved in the day-to-
day life of convicted sex offender Jeffrey Epstein, flying on his private planes over 360 times. Yet she
has only produced two responsive documents in this case. Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1097.0_1
6 pg
…videos, or other media depicting, any of
Epstein’s properties or airplanes.
11. All flight logs from Epstein’s planes.
12. All police reports concerning Giuffre.
13. All emails exchanged between Sarah Ransome and any member of the media, including…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.28_4
5 pg
…deal with it.. i had lisa svenson the swedish ocean
ambassador yesteady she said no one on her ocean panel takes this stuff seriously and you would be welcoe to
the ocean conferenec water conference etc.
On Sat, Jan 24…
giuffre-maxwell
gov.uscourts.nysd.447706.970.0
2 pg
…2009).
Even so, we respectfully suggest the status conference would be premature.
We are evaluating the Second Circuit’s opinion for purposes of petitioning the
Court for rehearing before the panel and/or en banc. We have substantial
Case 1…
giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…Maxwell, 929 F.3d 41,
54 (2d Cir. 2019) Before releasing the materials the Second Circuit panel did not
request review by the parties, did not hold a hearing, did not notify the parties which of
the 2,000 pages…
giuffre-maxwell
gov.uscourts.nysd.447706.1126.0
3 pg
…23, 2020 order of the District Court.
In the interest of judicial economy, any further appeal in this civil case shall be referred to
this panel.
The mandate shall issue forthwith.
FOR THE COURT:
Cather…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…CFPB
(/sites/articles/2016/04/11/argument-preview-gibson-dunns-olson-takes-aim-at-
cfpb/)
Split Panel Backs Tenancy for Disabled Woman's Son
(/sites/articles/2016/04/11/split-panel-ba…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…Witnesses.
A. Fair Trial / Evidence
As one “example” of a “countervailing value[],” the Brown panel specifically identified
“preserving ‘the right of an accused to fundamental fairness in the jury selection process.’” 929
F.3d at 54 n. 12 (quoting Press…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…2. While we appreciate the views
expressed in Judge Pooler’s separate opinion, the panel majority believes that the
efforts invested by three former district judges in reviewing these materials
adequately address those concerns.
23 Nixon, 435 U.S. at…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…Maxwell’s motion for summary judgment. (DE 586-3, Ex. 11 at 1-
197) The Second Circuit panel, despite the “strong presumption of access” afforded to summary
judgment documents, ruled that all of Ms. Maxwell’s questions and answers concerning…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…2. While we appreciate the views
expressed in Judge Pooler’s separate opinion, the panel majority believes that the
efforts invested by three former district judges in reviewing these materials
adequately address those concerns.
23 Nixon, 435 U.S. at…
giuffre-maxwell
gov.uscourts.nysd.447706.978.0
27 pg
…2. While we appreciate the views
expressed in Judge Pooler’s separate opinion, the panel majority believes that the
efforts invested by three former district judges in reviewing these materials
adequately address those concerns.
23 Nixon, 435 U.S. at…
giuffre-maxwell
gov.uscourts.nysd.447706.977.0
27 pg
…2. While we appreciate the views
expressed in Judge Pooler’s separate opinion, the panel majority believes that the
efforts invested by three former district judges in reviewing these materials
adequately address those concerns.
23 Nixon, 435 U.S. at…