giuffre-maxwell
gov.uscourts.nysd.447706.1331.27
11 pg
…11
Defendant Ghislaine Maxwell, through counsel, submits this Response to plaintiff’s
“Motion to Compel All Work Product and Attorney Client [sic] Communications with Philip
Barden” (Doc.637).
PROCEDURAL BACKGROUND
On February 24, 2016, we served on plaintiff’s counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.15
11 pg
…as Jeffrey Epstein and Leslie Groff,
cannot challenge this Court’s Protective Order. Therefore, the Court should summarily deny this
motion.
PROCEDURAL HISTORY
On March 18, 2016, this Court entered a Protective Order (DE 62) for the privacy of the…
giuffre-maxwell
gov.uscourts.nysd.447706.89.0
10 pg
…Letter Motions, and grant
Professor Cassell and Mr. Edward’s Motions to Appear Pro Hac Vice.
I. PROCEDURAL HISTORY
Upon Defendant’s April 6, 2016, Letter in opposition to Professor Cassell’s Motion for
Appearance Pro Hac Vice, the Court…
giuffre-maxwell
gov.uscourts.nysd.447706.928.0
11 pg
…Modify the Protective Order for the reasons set forth below. The Proposed
Intervenors are two non-parties, Jeffrey Epstein and Leslie Groff (“Epstein Defendants”).
PRELIMINARY STATEMENT
PROCEDURAL HISTORY
On March 18, 2016, this Court entered a Protective Order (DE 62…
giuffre-maxwell
gov.uscourts.nysd.447706.406.0
31 pg
… TABLE OF CONTENTS
Page
TABLE OF AUTHORITIES .......................................................................................................... ii
I. …
giuffre-maxwell
gov.uscourts.nysd.447706.26.1
26 pg
…Defendant. West Headnotes (37)
Civil Action No. 14–30211–MGM | Signed October 9,
2015 [1]
Federal Courts
Substance or procedur
giuffre-maxwell
gov.uscourts.nysd.447706.1289.0
3 pg
…at 1.1 Doe 171’s motion is procedurally and
substantively deficient and should be denied outright.
While Doe 171 filed her letter as a “motion to seal,” it is instead clearly a motion for
reconsideration governed by Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.1058.1
3 pg
…his case and in Maxwell allowing him access to all discovery materials and pleadings in Maxwell.
Of course, if the Court prefers a different procedural route to accomplish what he requests, then
Professor Dershowitz will follow the Court’s directive.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1302.0
3 pg
…after January 1, 2007, is permitted and is governed by Federal Rule of Appellate
Procedure 32.1 and this Court’s Local Rule 32.1.1. When citing a summary order in a document
filed with this Court, a party…
giuffre-maxwell
gov.uscourts.nysd.447706.1126.0
3 pg
…after January 1, 2007, is permitted and is governed by Federal Rule of Appellate
Procedure 32.1 and this Court’s Local Rule 32.1.1. When citing a summary order in a
document filed with this Court, a party…
giuffre-maxwell
gov.uscourts.nysd.447706.185.4
10 pg
…unnamed victims, Jane Doe 3 and Jane Doe 4, moved
to join as petitioners in this action pursuant to Federal Rule of Civil Procedure 21. (DE 280).
Petitioners (Jane Doe 1 and Jane Doe 2) support the Rule 21 Motion. …
giuffre-maxwell
gov.uscourts.nysd.447706.1025.0
17 pg
…for various reasons, most of which will be apparent,
e.g., the protocol did not address various substantive and procedural issues, it did not
account for the Court’s rulings and comments at the January 16 status conference, and,
in…
giuffre-maxwell
gov.uscourts.nysd.447706.422.0
8 pg
…Decl.
Ex. B. The parties have been unable to reach a resolution without the need for Court
intervention.
I. PROCEDURAL HISTORY
On February 12, 2016 Ms. Maxwell served her First Set of Discovery Requests on
Plaintiff. Request Number 19…
giuffre-maxwell
gov.uscourts.nysd.447706.542.5
11 pg
…unnamed victims, Jane Doe 3 and Jane Doe 4, moved
to join as petitioners in this action pursuant to Federal Rule of Civil Procedure 21. ( DE 280).
Petitioners ( Jane Doe 1 and Jane Doe 2) support the Rule 21 Motion. …
giuffre-maxwell
gov.uscourts.nysd.447706.363.4
11 pg
…unnamed victims, Jane Doe 3 and Jane Doe 4, moved
to join as petitioners in this action pursuant to Federal Rule of Civil Procedure 21. (DE 280).
Petitioners (Jane Doe 1 and Jane Doe 2) support the Rule 21 Motion. …
giuffre-maxwell
gov.uscourts.nysd.447706.1074.5
11 pg
…unnamed victims, Jane Doe 3 and Jane Doe 4, moved
to join as petitioners in this action pursuant to Federal Rule of Civil Procedure 21. (DE 280).
Petitioners (Jane Doe 1 and Jane Doe 2) support the Rule 21 Motion. …
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…A. The USVI’s Motion to Intervene Should be Granted.
Federal Rule of Civil Procedure 24 provides for intervention as of right by anyone
claiming “an interest relating to the property or transaction that is the subject of the action…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.13
22 pg
…writing a letter
to the court (as was the case here), insinuate itself into a private civil lawsuit
between others. The proper procedure, as the government should know, was either
to subpoena the deposition transcripts for use in a pending…
giuffre-maxwell
gov.uscourts.nysd.447706.1069.0
25 pg
…without
20 access to the entirety of the record in Giuffre v. Maxwell, the
21 procedural history, but when the Second Circuit spoke with
22 regard to this issue, it was very clear that there had been no
23 effective…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…her
That she relied on the Protective Order in answering questions, or refusing to
answer questions, is obvious from the procedural posture of the case:
• March 2, 2016 (DE 38): Defendant moved for a Protective Order, citing Plaintiff’s
anticipated…
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