giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…facsimiles,
contracts, offers, agreements, reports, objects, tangible things, work papers, transcripts, minutes,
reports and recordings of telephone or other conversations or communications, or of interviews
or conferences, or of other meetings, occurrences or transactions, affidavits, statements,
summaries, opinions, tests, experiments…
giuffre-maxwell
gov.uscourts.nysd.447706.749.0
9 pg
…26
19. Judge Marra’s ruling is relevant and admissible (Motion in Limine 19)....................... 29
20. The transcript of the tape recording of Mr. Dershowitz’s conversation with Rebecca
Boylan is admissible (Motion in Limine 20)................................................................. 31
C. Plaintiff’s…
giuffre-maxwell
gov.uscourts.nysd.447706.59.0
5 pg
…entries, as Ms. Giuffre’s
counsel has devoted significant resources to the evaluation of documents, and to recording their
content, with all deliberate speed in order to make all claims of privilege contemporaneously with the
Responses and Objections. Indeed, the…
giuffre-maxwell
gov.uscourts.nysd.447706.223.7
3 pg
…to the Subpoena
and all compliance efforts that may be sought or required under the Subpoena.
3. Mr. Epstein objects to videography as a form of recording of any deposition that
may occur.
4. Mr. Epstein objects to the Definitions…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.29
24 pg
…facsimiles,
contracts, offers, agreements, reports, objects, tangible things, work papers, transcripts, minutes,
reports and recordings of telephone or other conversations or communications, or of interviews
or conferences, or of other meetings, occurrences or transactions, affidavits, statements,
summaries, opinions, tests, experiments…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…of any nature and
computer interpretations thereof, instructions, announcements, and sound recordings of any
nature. “Document” also means all copies which are not identical to the original document as
originally written, typed or otherwise prepared. The term “Document” shall also…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.28
24 pg
…facsimiles,
contracts, offers, agreements, reports, objects, tangible things, work papers, transcripts, minutes,
reports and recordings of telephone or other conversations or communications, or of interviews
or conferences, or of other meetings, occurrences or transactions, affidavits, statements,
summaries, opinions, tests, experiments…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.32
27 pg
…work papers, transcripts, minutes,
reports and recordings of telephone or other conversations or communications, or of interviews
1
Case 1:15-cv-07433-LAP Document 1320-32 Filed 01/03/24 Page 9 of 27
or conferences, or of…
giuffre-maxwell
gov.uscourts.nysd.447706.223.1
14 pg
…Epstein
contracts, offers, agreements, reports, objects, tangible things, work papers, transcripts, minutes,
reports and recordings ofteJcphone or other conversations or communic.ations, or of interviews
or conferences, 01' of other meetings, occurrences or transactions, affidavits, statements,
sllmmaries, opinions, tests, experiments…
giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…memorandum, telegram, chart, report, recording, disk, etc.; (h) its title
and subject matter (without revealing the information as to which the privilege is claimed); (i)
with sufficient specificity to permit the Court to make full determination as to whether the…
giuffre-maxwell
1320-32
27 pg
…work papers, transcripts, minutes,
reports and recordings of telephone or other conversations or communications, or of interviews
1
Case 1:15-cv-07433-LAP Document 1320-32 Filed 01/03/24 Page 9 of 27
or conferences, or of…
giuffre-maxwell
gov.uscourts.nysd.447706.57.3
39 pg
…they were cooperating fully. The proposed deliverables include ‘make
recommendations for measures to be put in place to prevent a recurrence’, ‘reappraise
existing risk assessments’ and ‘satisfy legal reporting and recording duties’. It is also
stated that, ‘due to the…
giuffre-maxwell
gov.uscourts.nysd.447706.222.0
10 pg
…granted.
II. If Mr. Epstein is Required to Submit to a Deposition, Recording by Videography
Should Not Be Permitted
If Mr. Epstein is required to submit to a deposition, the subpoena should be modified to
prohibit videography. Trial preparation is…
giuffre-maxwell
gov.uscourts.nysd.447706.730.0
14 pg
…Numerous courts, including this one, have admitted FBI 302s under this
authority. The statement is also trustworthy because it is simply the FBI’s recording of Ms.
Giuffre’s own statement and, of course, Ms. Giuffre is fully available to…
giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…435 U.S. at 609] explained, in declining to compel
the release of audio tapes, that the public interest in accessing audio recordings is
weaker where “[r]eporters also were furnished transcripts of . . . tapes,” reasoning
that the fact that “[t…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…16 Shield Law material. They list it at a couple of different
17 points in their brief. They are asking for Sharon Churcher's
18 interview notes, recordings, memos, and other documentation
19 that are clearly, and concededly by the…
giuffre-maxwell
gov.uscourts.nysd.447706.503.0
21 pg
…burden has been met, "[a] party contending
that a subpoena should be quashed pursuant to Rule
45 (c) (3) (A) (iv) must demonstrate that compliance with the
subpoena would be unduly burdensome." Bridgeport Music Inc. v.
UMG Recordings, Inc., No…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.15
43 pg
…P. 37(a)(l).
A party contending that a subpoena should be quashed pursuant to Rule 45(c) (3)(A)(iv)
must demonstrate that compliance with the subpoena would be unduly burdensome." Bridgeport
Music Inc. v. UMG Recordings, Inc., No…
giuffre-maxwell
gov.uscourts.nysd.447706.829.0
4 pg
…Y. May 2, 2014) (denying motion to
designate as confidential all videotaped depositions and other recordings, and
noting that Rule 26(c) standard of good cause “ordinarily requires a party to
show that disclosure will result in a clearly defined…
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