giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…Preska
November 16, 2019
Page 3
numbers,” and “the names of alleged minor victims of sexual abuse from deposition
testimony and police reports, as well as deposition responses concerning intimate
matters where the questions were likely only permitted—and the…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…rights reserved. Registration or use of this site constitutes acceptance of our Terms of Service
and Privacy Policy.
Case 1:15-cv-07433-LAP Document 363-11 Filed 08/11/16 Page(https://store.law.com/registration/default.aspx?…
giuffre-maxwell
gov.uscourts.nysd.447706.406.0
31 pg
…criminal investigation. Back in 2005, when the Palm Beach
Police Department was first investigating Epstein’s sexual abuse, the Department accumulated
overwhelming evidence placing underage girls at Epstein’s residence who gave statements that
they were being sexually abused, the…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…07433-LAP Document 1057 Filed 06/10/20 Page 4 of 17
excerpts from Ms. Maxwell’s deposition. Exhibit 3 contains pages from the Palm Beach Police
Report. DE 149 is Ms. Maxwell’s response to DE 143.
Page 2…
giuffre-maxwell
gov.uscourts.nysd.447706.135.0
37 pg
…8~ . 3,7.3, ,..448 ' ~ ~: E ;2 dJ 1_2:1 ., i. ·
(1983). The policy purposes 6f privilege in both jurisdictions
also mi..r ~fn
giuffre-maxwell
gov.uscourts.nysd.447706.1215.0
13 pg
…at 1; contra DE 406 at 19 (“And again, the
Court should not lose sight of the policy rationale behind the First Amendment right of access:
the accountability of the courts to the public.”). Now that it is Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…Apr. 22, 2014). Although the “the federal and state policies” on the reporter’s
privilege are “congruent,” id. *4, as discussed further herein, the standards for overcoming the privilege are higher
when the state Shield Law applies.
2
Case…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.3_1
2 pg
…likely because there is none. GM 748-840 are various
police reports that have been publicly available for years. GM 841-849 are
public comments about your client's story which are available to the world by
a simple Google…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.4_1
4 pg
…likely because there is none."). I
disagree.
Your latest produc6on includes a police report detailing the rape of a 14 year old child,
my client. Other materials you produced include police records concerning my client while she
was a minor…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.13_1
3 pg
…that this is fishing with a drift net. We decline your
request to engage in this exercise.
Regarding redacted police reports that plaintiff designated “confidential”: We
objected to plaintiff’s confidentiality designation, and plaintiff failed to file a
motion in…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.5_1
3 pg
…fairly obvious that this is fishing with a drift net. We decline your
request to engage in this exercise.
Regarding redacted police reports that plaintiff designated “confidential”: We
objected to plaintiff’s confidentiality designation, and plaintiff failed to file a
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…against others, her claims were rejected by the police ‘due to
..VR..lack of credibility.”
The new interest in this old settled case results from lawyers representing some of
JE victims filed a suit against the US government, not JE…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.13
22 pg
…Id. at 1089. This type of
overbroad subpoena is exactly what the Fourth Amendment is designed to prohibit: searches that
invade “the privacies of life” from “arbitrary” power and “police surveillance” that is “too
permeating.” See Carpenter, 138 S. Ct…
giuffre-maxwell
gov.uscourts.nysd.447706.1312.0
9 pg
…“It’s not the
job of the Court to police press coverage and alert the public when reporting on unsealed materials
concerning intimate matters where the questions were likely only permitted—and the responses
only compelled—because of a strong…
giuffre-maxwell
gov.uscourts.nysd.447706.1237.0
20 pg
…g
Tr. 7:5-8 (“It’s not the job of the Court to police press coverage and alert the public when reporting
on unsealed materials as yesterday’s news when the unsealed material is already public.”).8
Further, Does…
giuffre-maxwell
gov.uscourts.nysd.447706.66.0_1
35 pg
…times with Jeffrey Epstein, 20 of which were with my
5 client when she was underage. We have the Palm Beach police
6 report, which shows over 30 minors who reported during that
7 time period, to up until now…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…media moguls, and high
profile business-people. Police departments regularly post mugshots and names of working-class
prostitution clients who get ensnared in street-level prostitution stings. That is considered to be a
matter of public concern. It is virtually…
giuffre-maxwell
gov.uscourts.nysd.447706.1213.0
18 pg
…from the articles themselves. Id. at 2–3.
2
Case 1:15-cv-07433-LAP Document 1213 Filed 02/12/21 Page 7 of 18
guards against the miscarriage of justice by subjecting the police, prosecutors, and judicial
processes…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…exercising its inherent “supervisory powers.”26 A
security numbers. We have also redacted the names of alleged minor victims of
sexual abuse from deposition testimony and police reports, as well as deposition
responses concerning intimate matters where the questions were…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.39
36 pg
…times with Jeffrey Epstein, 20 of which were with my
5 client when she was underage. We have the Palm Beach police
6 report, which shows over 30 minors who reported during that
7 time period, to up until now…
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