giuffre-maxwell
gov.uscourts.nysd.447706.648.0
4 pg
…Subsequent to the hearing on February 16, 2017 the parties have conferred extensively
about the viability of the existing case management deadlines. The parties agree that the
previous deadlines are no longer tenable. Accordingly, subject to the Court' s approval…
giuffre-maxwell
gov.uscourts.nysd.447706.1315.0
51 pg
…ORDER
GHISLAINE MAXWELL,
Defendant.
LORETTA A. PRESKA, Senior United States District Judge:
The Court reiterates here its previous recitation of the applicable law and
descriptions of the unsealing process set out in the transcripts dated January 19, 2021
(dkt. no…
giuffre-maxwell
gov.uscourts.nysd.447706.1129.0_5
2 pg
…response to Plaintiff’s letter of today’s date, purporting to confirm that her
counsel may release “later today” the previously unsealed deposition testimony of Ms.
Maxwell and Doe 1 (“Unsealed Materials”), while redacting Doe 1’s name from the…
giuffre-maxwell
gov.uscourts.nysd.447706.382.0
2 pg
…in my August 11, 2016 declaration in
support of my pending motion to intervene and to unseal documents.
2. In my previous declaration, I characterized the offenses to which Jeffrey Epstein
pleaded guilty as “involving sex with minors” (¶ 7) and…
giuffre-maxwell
gov.uscourts.nysd.447706.1353.0
6 pg
…the Government respectfully moves to unseal—in a limited fashion—various
materials previously produced by the law firm of Boies Schiller Flexner LLP to the Government
pursuant to a Grand Jury subpoena (the “Materials”) during the grand jury investigation of…
giuffre-maxwell
gov.uscourts.nysd.447706.375.0
4 pg
…ed. 2004) (“Motions, briefs, or
memoranda ... may not be attacked by the motion to strike.”).
This Court recently denied Defendant’s previous attempt to strike Ms. Giuffre’s Motion
for Adverse Inference Instruction (July 22, 2016 Order D.E. 301)…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.17
12 pg
…did obtain the information from other sources making a third deposition of
Ms. Maxwell improper.
LEGAL STANDARD
“A person who has previously been deposed in a matter may be deposed again, but only
with leave of the court.” Sentry Ins…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.14
9 pg
…or records relating to the
massages. The Defendant has opposed the motion on the grounds that the
questions were repetitive and her previous deposition testimony answered the
questions posed. Directions not to answer except on the grounds of privilege or
…
giuffre-maxwell
gov.uscourts.nysd.447706.1312.0
9 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.447706.1318.0
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.447706.1332.12
7 pg
…not
agree to the appointment of a special master to oversee Ms. Maxwell’s third deposition.
INTRODUCTION
Plaintiff has deposed Defendant for more than thirteen hours of testimony on the record.
During the previous depositions, a variety of issues arose…
giuffre-maxwell
gov.uscourts.nysd.447706.89.0
10 pg
…519 F.3d 1123 (10th
Cir. 2008) (arguing for opportunity for victim to deliver a victim impact statement). His previous
experience will be valuable to Ms. Giuffre as this case proceeds. Professor Cassell is also located
in Salt Lake City…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…A. Ms. Maxwell incorporates by
reference the Countervailing Interests she previously briefed and the legal bases therefore. See
DE 1057.1
The Second Circuit already determined that Ms. Maxwell’s July 2016 deposition was
compelled and that her answers related…
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…dated Mar. 17, 2016 [dkt.
no. 62].) As previously observed by the Court, that protective
order is “unremarkable in form and function” in that it, like most
protective orders, seeks to “protect the discovery and
dissemination of confidential information or…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.23
10 pg
…pleading. Ms. Maxwell has never
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 Joe Recarey never “testified that Defendant
procured underage girls for…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.16
6 pg
…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, or a person responsible for delivering…
giuffre-maxwell
gov.uscourts.nysd.447706.99.0
22 pg
…supplement” her privilege log, specifically identify some of the
documents she is withholding, produce relevant documents clearly in her possession, concede to
providing information previously withheld, or provide previously requested verification of her
interrogatory responses. Even then, the supplemental information…
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.447706.102.0
9 pg
…leave to provide such
information to the Court via an ex parte, in camera submission.
I. Background
As the Court is well aware from previously filed pleadings, this is a single-count
defamation case, turning on whether Defendant defamed Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.1
8 pg
…Giuffre’s counsel sent a
follow up letter on July 8, 2016 requesting that Defendant also search a previously undisclosed e-
mail address for Defendant that Ms. Giuffre discovered when reviewing a FOIA production from
the Palm Beach County State…
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