giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…the July 3,
2019 Opinion of the United States Court of Appeals for the Second Circuit directed this Court to
perform a “particularized review” of materials previously filed under seal in this matter (the
“Sealed Materials”) to determine whether they…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
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.447706.1090.6
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
1320-9
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.447706.1325.3
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.447706.31.0_1_1
22 pg
… What, if anything, were they in
4 response to?
5 Your Honor has found in previous cases, such as
6 Hawkins v. City of New York, that the failure to identify the
7 individuals to whom the statement allegedly was…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.35
10 pg
…Ms. Maxwell has never “admitted” to having
“threesomes with multiple different girls.” (Reply at 4). That is a misstatement of fact
compounded by Plaintiff’s intentional omission of the previous page of deposition testimony
which exposes the falsehood. Similarly, Detective…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.18
23 pg
… What , if anything, were they in
4 response to?
5 Your Honor has found in previous cases, such as
6 Hawkins v . City of New York, that the failure to identify the
7 individuals to whom the statement allegedly was…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.6
10 pg
…in the discovery phase of this
case, particularly where any answers will be maintained as confidential under the Protective
Order entered in this case.
As the Court is aware from previous pleadings, at the heart of this case lies the…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.10_2
10 pg
…in the discovery phase of this
case, particularly where any answers will be maintained as confidential under the Protective
Order entered in this case.
As the Court is aware from previous pleadings, at the heart of this case lies the…
giuffre-maxwell
1320-6
10 pg
…in the discovery phase of this
case, particularly where any answers will be maintained as confidential under the Protective
Order entered in this case.
As the Court is aware from previous pleadings, at the heart of this case lies the…
giuffre-maxwell
gov.uscourts.nysd.447706.1285.0
6 pg
…trauma as a result
of the events” described in the Confidential Records; (b) the materials allegedly
pertaining to Doe 171 in the Confidential Records had ever been previously
disclosed before; and/or (c) the materials allegedly pertaining to Doe 171…
giuffre-maxwell
gov.uscourts.nysd.447706.1286.0
6 pg
…trauma as a result
of the events” described in the Confidential Records; (b) the materials allegedly
pertaining to Doe 171 in the Confidential Records had ever been previously
disclosed before; and/or (c) the materials allegedly pertaining to Doe 171…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…a hearing. During that hearing, victim’s counsel (having previously made a
proffer of the relevant circumstances to Government counsel) orally moved to have Jane Doe
No. 2 added into the case as another “victim” under the CVRA. Government counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…make
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 132-1 Filed 05/01/16 Page 16 of 31
15
G4LMGIUC
1 her story consistent with her previous stories. She has
2…
giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…and could result in some unfortunate
association between the non-parties and Jeffrey Epstein or Ghislaine Maxwell. But as the Court
has previously recognized, such generalized concerns about annoyance or embarrassment are
insufficient to overcome the presumption of public access…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…of the employees in Epstein’s mansion. Mr. Alessi
provided witness statements to police during the criminal investigation in Palm Beach, and was
previously deposed in civil cases previously brought against Mr. Epstein. Specifically, Juan
Alessi informed the Palm Beach…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.22
22 pg
…VAGINAL
INTERCOURSE ON HER. I ASKED ABOUT SUSPECT NUMBER 1 FORCING ORAL
SEX ON HER AS SHE PREVIOUSLY AND SHE SAID THAT HE FORCED THE HEAD
OF HIS PENIS IN HER MOUTH. iii&lifl SAID THAT SHE TOLD THE SUSPECTS…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.15
6 pg
…El Brillo mansion? 19
20 MR. REJNHART: Objection to the form, same as 20
21 the previous question. It assumes knowledge of a 21
22 place known as the El Brillo mansion and a person 22
23 bythenameofJaneNo. 103. ltiscompoundand …
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…Mr.
Gow’s communication to the British press. Any such articles or coverage of which she is aware
have previously been produced in this action and are equally available to both parties in the
public domain.
4. Identify all legal…
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