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.447706.1129.0_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.447706.712.0
11 pg
…reason having been provided why
this important witness should not have to appear at trial, the motion to quash should be denied.
BACKGROUND
As the Court is aware from previous briefing, Jeffrey Epstein is an important witness in this
case…
giuffre-maxwell
gov.uscourts.nysd.447706.592.0
5 pg
…Maxwell’s previously
lodged objections to the various designations made by the Plaintiff and subject to anticipated
motions in limine regarding various evidentiary and legal issues in this matter.
Case 1:15-cv-07433-LAP Document 592 Filed 02…
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.447706.1201.24
4 pg
…hereby certify
5 that I am a Registered Professional Reporter and
6 Notary Public within the State of Colorado; that
7 previous to the commencement of the examination, the
8 deponent was duly sworn to testify to the truth.
9 …
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.447706.1328.35
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.447706.1257.23
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.447706.563.0
10 pg
…and
there is, accordingly, no need to resort to previously video recorded deposition testimony.
PRELIMINARY STATEMENT
Defendant has designated for use in this trial various excerpts from Ms. Giuffre’s video
recorded deposition in a state court case. It appears…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…at 180–82.
1. Undecided Motions1
Plaintiff’s Position: Mindful of the Court’s directive that “the parties’ proposals should accord
with the Unsealing Protocol previously issued by this Court, including with respect to
identification and notification of any affected…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.27
6 pg
…Q (BY MS. MENNINGER) Dr. Olson, have you
44
17 17 been deposed previous to today?
18 18 A No.
19 …
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.447706.1106.0_2
6 pg
…Page 2 of 6
Page 2 of 6
Doe’s letter in opposition to the Joint Letter submitted to the Court by the parties in
Dershowitz rehashes the arguments he has made previously regarding the unsealing of documents
in Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…meet Ms. Maxwell or Mr. Epstein in 1999 (or in 1998) at the age of 14 or 15, as she
previously has sworn and as she told members of the press. Declaration of Jeffrey S. Pagliuca
“Pagliuca Decl.”), Composite Ex…
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.447706.1209.1
24 pg
…1 8.24.16 No objection to unsealing
398-2 8.24.16 Public document.
398-3 8.24.16 No objection to unsealing
Previously Partially
398-4 8.24.16 Partially unsealed on remand
…
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