giuffre-maxwell
gov.uscourts.nysd.447706.895.0
3 pg
…Morgan & Foreman, P.C., counsel of record for Defendant
Ghislaine Maxwell (“Maxwell”) in this action. I respectfully submit this declaration in
support of Ms. Maxwell’s Response In Opposition to Plaintiff’s Notice Pursuant to Rule 415
of Similar Acts…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…Defendant.
/
THE GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS’
MEMORANDUM OF LAW IN SUPPORT OF EX PARTE MOTION TO INTERVENE
AND FOR CONFIDENTIAL ACCESS TO JUDICIAL RECORDS AND DISCOVERY
DOCUMENTS
The Government of the United States Virgin Islands (the “USVI…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.34
4 pg
…P.C., counsel of record for Defendant
Ghislaine Maxwell (“Maxwell”) in this action. I respectfully submit this declaration in support of
Defendant’s Motion for Rule 37(b) &(c) Sanctions for Failure to Comply with Court Order and
Failure to…
giuffre-maxwell
1320-34
4 pg
…P.C., counsel of record for Defendant
Ghislaine Maxwell (“Maxwell”) in this action. I respectfully submit this declaration in support of
Defendant’s Motion for Rule 37(b) &(c) Sanctions for Failure to Comply with Court Order and
Failure to…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.17
4 pg
…the Clerk of Court by using the CM/ECF system. I also certify that the foregoing
document is being served to all parties of record via transmission of the Electronic Court Filing
System generated by CM/ECF.
Laura A. Menninger…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…Abuse” Does Not Warrant Continued Sealing. ................. 9
C. The Protective Order Does Not Warrant Continued Sealing. ................................... 10
D. The “Abuse of Court Records and Files” Does Not Warrant Continued Sealing. ... 12
E. “Annoyance, Embarrassment, Oppression, a…
giuffre-maxwell
gov.uscourts.nysd.447706.308.0
7 pg
…1, Affidavits of
Service of Process related to Kellen; and Exhibit 2, July 21, 2016, Deposition Record Transcript.
The subpoena directed that Ms. Kellen appear at the offices of Boies, Schiller, and Flexner in
New York on July 21, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.33
24 pg
…Comply with Rule 26(a), stating
as follows:
CERTIFICATE OF CONFERRAL
The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an
attempt to obtain records and interrogatory responses Ordered by the Court, including by letter
dated April…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.1_2
24 pg
…Comply with Rule 26(a), stating
as follows:
CERTIFICATE OF CONFERRAL
The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an
attempt to obtain records and interrogatory responses Ordered by the Court, including by letter
dated April…
giuffre-maxwell
1320-33
24 pg
…Comply with Rule 26(a), stating
as follows:
CERTIFICATE OF CONFERRAL
The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an
attempt to obtain records and interrogatory responses Ordered by the Court, including by letter
dated April…
giuffre-maxwell
gov.uscourts.nysd.447706.712.0
11 pg
…the Clerk of Court by using the CM/ECF system. I also certify that the
foregoing document is being served to all parties of record via transmission of the Electronic
Court Filing System generated by CM/ECF.
Laura A. Menninger…
giuffre-maxwell
gov.uscourts.nysd.447706.231.0
23 pg
…Comply with Rule 26(a), stating
as follows:
CERTIFICATE OF CONFERRAL
The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an
attempt to obtain records and interrogatory responses Ordered by the Court, including by letter
dated April…
giuffre-maxwell
gov.uscourts.nysd.447706.375.0
4 pg
…the Clerk of Court by using the CM/ECF system. I also certify that the foregoing
document is being served to all parties of record via transmission of the Electronic Court Filing
System generated by CM/ECF.
Laura A. Menninger…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…Palm Beach County State Attorney as part of
-
the investigation and prosecution of Epstein.
M Ghislaine Maxwell
See (DE 280-2), Palm Beach County State Attorney’s Office, Public Records Request No.: 16-
268, Disc 7 at p. 2305 (GIUFFRE007843)…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…Moreover, as noted above, the record is replete with
multiple examples of Defendant failing to recall obvious and highly incriminating facts. Given
Defendant’s amnesia about important events, it seems obvious that she may similarly be
17
Case 1:15…
giuffre-maxwell
gov.uscourts.nysd.447706.561.0
22 pg
…only knew that the
statements were false but indeed actively participated in fabricating false
statements. The record is completely devoid of evidence to support the existence
of any such basis.
McCawley Dec., Exhibit 2 (Summary Judgment Motion) at 12.
Ultimately…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…over to the Palm
Beach County State Attorney as part of the investigation and prosecution of Epstein:
See (DE 280-2), Palm Beach County State Attorney’s Office, Public Records Request No.: 16-
268, Disc 7 at p. 2305 (GIUFFRE007843).
…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…over to the Palm
Beach County State Attorney as part of the investigation and prosecution of Epstein:
See (DE 280-2), Palm Beach County State Attorney’s Office, Public Records Request No.: 16-
268, Disc 7 at p. 2305 (GIUFFRE007843).
…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…over to the Palm
Beach County State Attorney as part of the investigation and prosecution of Epstein:
See (DE 280-2), Palm Beach County State Attorney’s Office, Public Records Request No.: 16-
268, Disc 7 at p. 2305 (GIUFFRE007843).
…
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