giuffre-maxwell
gov.uscourts.nysd.447706.610.0
3 pg
…filed under seal in relation
to Defendant’s pending motion for summary judgment. Dershowitz relies upon and incorporates
by reference his previous submissions in support of his motion to unseal certain documents in
this case (see ECF Nos. 362-64…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…join in this action to vindicate their rights as well.
Because the new victims will not re-litigate any issues previously litigated by the current victims
(and because they are represented by the same legal counsel as the current victims…
giuffre-maxwell
gov.uscourts.nysd.447706.1318.0
3 pg
…1315). We had not previously submitted those
materials because I was not previously attorney of record in the district court
and therefore was not on the ECF service list, and therefore did not receive the
Court’s endorsement of October…
giuffre-maxwell
gov.uscourts.nysd.447706.1317.0
3 pg
…1315). We had not previously submitted those
materials because I was not previously attorney of record in the district court
and therefore was not on the ECF service list, and therefore did not receive the
Court’s endorsement of October…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.5
4 pg
…maybe I would
21 recognize it, but I don't believe I'd
22 remember him.
23 Q. Did you ever go to the Dubin
24 residence with some woman who had previously
25 been with Mr. Epstein?
Confidential…
giuffre-maxwell
gov.uscourts.nysd.447706.751.10
4 pg
…15-cv-07433-LAP Document 751-10 Filed 03/17/17 Page 3 of 4
But the woman's allegations have previously been firmly rejected by Buckingham Palace.
"It is emphatically denied that the Duke of York had any form…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.16
2 pg
…settlement of this action, Intervenor anticipated the possibility that this Court might be faced with
an unsealing motion, or one to de-designate certain materials previously designated as
“confidential” under the Protective Order in this case. Accordingly, in the June…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.17
16 pg
…the Ransome deposition—an action
that would require modification of the Protective Order in this case —it also simultaneously
remove the confidentiality designation from several related emails and attachments that the
parties previously designated confidential (RANSOME_000273-557) (“the Emails”)…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.15_1
4 pg
…maybe I would
21 recognize it, but I don't believe I'd
22 remember him.
23 Q. Did you ever go to the
24 with some woman who had previously
25 been with Mr. Epstein?
Confidential
Page 197…
giuffre-maxwell
gov.uscourts.nysd.447706.233.0
9 pg
…owns a mansion where he regularly resides
in New York City. Epstein does admit, however, that “it is not common to bar a deposition from
occurring” (id.) – a point that this Court has previously emphasized. See, e.g., Naftchi v…
giuffre-maxwell
gov.uscourts.nysd.447706.362.0
2 pg
…and for an Order unsealing certain documents previously filed with the Court,
or in the alternative for an Order modifying the Protective Order previously entered by the Court,
together with such other and further relief as this Court deems just…
giuffre-maxwell
gov.uscourts.nysd.447706.2.0
2 pg
…jurisdiction. 28 U.S.C.1332
Has th is action. case, or proceeding, or one essentially the same been previously filed in SONY at any time? Nfiles0iudge Previously Assigned
If yes, wa s this case Vol. D In vol. D…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.44
14 pg
…I must invoke my Fifth Amendment tight. 1 :t 5 that it assumes knowledge of Jeffrey Epstein.
16 BY MR.K(.JVlN: \ 16 Standing objection a.~ previously stated with.
17 Q. Have you eve-r heard of the Ghislaine…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.14
4 pg
…and any documents, files or previous e-mail messages
attached to it may contain information that is confidential or legally privileged. If you are not the intended
2
Case 1:15-cv-07433-LAP Document 1327-14 Filed 01…
giuffre-maxwell
gov.uscourts.nysd.447706.55.10
10 pg
…understanding is that it's a
6 combination; that is, it reflects the previous
7 agreement and that there is a new agreement that
8 supplemented the previous agreement.
9 BY MR. EDWARDS:
10 Q. When you say it's…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.2
73 pg
…someone would 2 home to give him a massage, other than
3 come in and sit and chat to me while I was 3 someone who had previously given you a
4 getting a massage, a friend would come in…
giuffre-maxwell
gov.uscourts.nysd.447706.239.1
11 pg
…[email protected]
www.hmflaw.com
CONFIDENTIALITY NOTICE: This e-mail transmission,
and any documents, files or previous e-mail messages
attached to it may contain information that is
confidential or legally privileged. If you are not the
intended recipient…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…produced in this case identify the date of employment as 2000, and she recalls being
there in the summer. Ms. Giuffre previously attempted to gather employment records
from Mar-A-Lago. See Giuffre002726. She earned approximately $9 per hour. The
…
giuffre-maxwell
gov.uscourts.nysd.447706.1119.0_3
4 pg
…Dershowitz, see DE 1071, and the
same result attains here.
As the Court is well-aware, and has been briefed at length previously, see DEs 1062,
1105, under circumstances such as these, the Court should not modify the Protective Order…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…produced in this case identify the date of employment as 2000, and she recalls being
there in the summer. Ms. Giuffre previously attempted to gather employment records
from Mar-A-Lago. See Giuffre002726. She earned approximately $9 per hour. The
…