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.447706.1320.9
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.447706.811.0
2 pg
…| Case No.: 15-cv-07433-RWS
Dear Judge Sweet:
Movant-Intervenor Michael Cernovich d/b/a Cernovich Media was previously unable to
divine from the publicly available portions of Plaintiff’s Notice of Intent to Request
Redaction (Doc No…
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.447706.89.0
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.447706.1328.35
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.447706.1161.0_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.447706.1320.6
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
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.447706.99.0
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
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.447706.102.0
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.447706.1264.0
1 pg
…of public access to judicial documents against the privacy, reputational, and
other countervailing interests that support the continued sealing of certain of the previously
sealed materials in this case. See id. TGP’s motion seeks to discard this protocol and…
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.447706.751.10
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…
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