giuffre-maxwell
gov.uscourts.nysd.447706.542.3
2 pg
…com
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giuffre-maxwell
gov.uscourts.nysd.447706.24.2
2 pg
…7454
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giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…that he never saw any naked photos at Epstein’s Palm Beach mansion, the
recently released video taken by the Palm Beach Police department during its investigation, reveals naked photos in
a number of the common areas of Epstein’s…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…brief
11 on this matter.
12 We wrote a letter to opposing counsel citing some
13 governing provisions of Microsoft's email policy that indicates
14 that due to inactivity they delete accounts after a certain
15 amount of time…
giuffre-maxwell
gov.uscourts.nysd.447706.503.0
21 pg
…"New York public
policy as embodied in the Constitution and our current statutory
scheme provides a mantle of protection for those who gather and
report the news-and their confidential sources-that has been
recognized as the strongest in the…
giuffre-maxwell
gov.uscourts.nysd.447706.46.0
22 pg
…law of the country that has
the predominant or the most direct and compelling interest in whether [the] communications
should remain confidential, unless that foreign law is contrary to the public policy of this forum.”
Anwar v. Fairfield Greenwich Ltd.…
giuffre-maxwell
gov.uscourts.nysd.447706.193.0
14 pg
…allegedly defamatory statements at issue. New York therefore has the
predominate interest in whether these communications remain confidential. The similarity
between New York and British attorney-client privilege demonstrates that no public policy
conflict exists. Consequently, New York law applies…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.22
31 pg
…that he never saw any naked photos at Epstein’s Palm Beach mansion, the
recently released video taken by the Palm Beach Police department during its investigation, reveals naked photos in
a number of the common areas of Epstein’s…
giuffre-maxwell
gov.uscourts.nysd.447706.140.3
4 pg
…a doctor by alleged minor victims of sexual abuse, to bar
disclosure of documents related to police officers’ questioning of nonparty victims in connection with a criminal
investigation of the doctor, inasmuch as disclosure could imperil future investigations and have…
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.447706.1150.3_2
12 pg
…news/ghislaine-maxwell-denied-inappropriate-action-by-jeffrey-epstein-in-newly-released-2016-deposition/
232 https://www.washingtonexaminer.com/policy/courts/ghislaine-maxwell-repeatedly-pushed-back-on-epstein-sexual-misconduct-allegations-unsealed-deposition-revea
233 https://www.mynspr.org/post…
giuffre-maxwell
gov.uscourts.nysd.447706.57.2
30 pg
…all of which would be consistent with the policy
Case 1:15-cv-07433-RWS Document 57-2 Filed 03/14/16 Page 12 of 30
underlying privilege and with a common sense application of that policy to the
practicalities…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…Background ........................................................................................................................ 2
I. THE DOCUMENTS AT ISSUE ARE NOT CONFIDENTIAL............................................. 4
A. Plaintiff’s Police Records Are Publicly Available from Law Enforcement Agencies in
…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.26
4 pg
…a name? Ask Good Morning America.
ABC News staffers were so upset that GMA had hired ex-L.A. police detective Mark Fuhrman as a consultant that his title
was changed, GMA chief Shelley Ross confirmed Wednesday.
Fuhrman, who pled…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.11
13 pg
…This Court should Order Production of Documents Responsive to Requests
Nos. 1-3
Defendant characterizes the police reports (and information therein) concerning Ms.
Giuffre as a minor as both “highly relevant” (Br. at 4) and “irrelevant” to this action (Br…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.6_1
14 pg
…Background ........................................................................................................................ 2
I. THE DOCUMENTS AT ISSUE ARE NOT CONFIDENTIAL............................................. 4
A. Plaintiff’s Police Records Are Publicly Available from Law Enforcement Agencies in
…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.3_1
4 pg
… Attached hereto as Exhibit 3, is a true and correct copy of the Palm Beach Police
Report.
Case 1:15-cv-07433-LAP Document 1090-3 Filed 07/30/20 Page 2 of 4
6. Attached hereto as Exhibit…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.2
12 pg
…the question please and break it down so it's more understandable.
Q. Now that you have the police report that I showed you this morning that you had an
opportunity to look at.
A. You gave it to me…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.2
26 pg
…category, victim
4 information, and then we have listed, I believe, a
5 total of 17 individuals that the Palm Beach Police
6 Department incident report lists as alleged victims
7 in this case, correct?
8 A. Correct.
9 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.10
15 pg
…7
8 E X H I B I T S
9 Deposition Exhibit 1 6
Police Interview
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MAGNA9 LEGAL SERVICES
Case 1:15-cv…