giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…redacted information, those concerns should be allayed by the September 13, 2007 Stipulated
Protective Order”).
In this case, unlike Maxwell who has refused to produce documents, Ms. Giuffre has
produced a number of documents including turning over personal, embarrassing documents…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…annoyance or embarrassment if unsealed” because, inter alia, she “refused to testify as to any
consensual adult activity behavior and generally disclaimed any knowledge of underage
activity.” TR 7/23/2020, p 4. This Court declined to keep sealed this…
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…2021
Page 3
be a renewed attempt to re-serve the Non-Parties with no return address, but Maxwell refused
because her objection would remain even for a Non-Party that was actually served but did not
object. In short…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…Mr. Rizzo’s testimony about how
Defendant took the passport of a 15-year-old Swedish girl and threatened her when she refused
to have sex with Epstein cannot be given to the media.6 Likewise Mr. Alessi’s testimony…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…Co., 594
F.2d 291, 296–97 (2d Cir. 1979) (“In the present case the deponents testified in reliance upon the
Rule 26(c) protective order, absent which they may have refused to testify. . . . [T]he witnesses
were entitled to…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.33
24 pg
…As to both, Ms. Maxwell provided releases for Plaintiff’s signature.
On March 16, 2016, Plaintiff refused to provide the names of any of Plaintiff’s treating
physicians, nor the requested releases, claiming “privilege.” Menninger Decl., Ex. A.
On March…
giuffre-maxwell
gov.uscourts.nysd.447706.949.0
31 pg
…refused to answer a number of
16 questions related to what I will loosely characterize as her
17 "adult sexual conduct."
18 We were back in front of the Court on a plaintiff's
19 motion to compel answers to…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.9
21 pg
…Civ. P. 26(f) (3) (C) . Defendant having
admitted to deletion practices that indicate relevant documents
and also refused to detail document search methods, good cause
exists to warrant court supervised examination of her electronic
devices. Accordingly, Plaintiff's motion…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.1_2
24 pg
…As to both, Ms. Maxwell provided releases for Plaintiff’s signature.
On March 16, 2016, Plaintiff refused to provide the names of any of Plaintiff’s treating
physicians, nor the requested releases, claiming “privilege.” Menninger Decl., Ex. A.
On March…
giuffre-maxwell
gov.uscourts.nysd.447706.63.0
22 pg
…Walls v. Paulson, 250 F.R.D. 48 (D.D.C. 2008) (sanctioning Plaintiff for
failure to sign interrogatories) (internal citations omitted).
5
Plaintiff refused to answer at all Interrogatory Nos. 5-14. Id. at 10-17. With respect…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.0
9 pg
…and that principles of fairness mandated
enforcement of the protective order.” Id. The Second Circuit affirmed:
In the present case the deponents testified in reliance upon the Rule 26(c)
protective order, absent which they may have refused to testify. . …
giuffre-maxwell
1320-33
24 pg
…As to both, Ms. Maxwell provided releases for Plaintiff’s signature.
On March 16, 2016, Plaintiff refused to provide the names of any of Plaintiff’s treating
physicians, nor the requested releases, claiming “privilege.” Menninger Decl., Ex. A.
On March…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.8
29 pg
…made false accusations of sexual assault against a number of
individuals; ultimately the prosecutor refused to prosecute a sexual assault case against them.
The police reports were produced to Plaintiff’s counsel in April 2016.
1
In response, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…09/03/19 Page 5 of 10
September 3, 2019
Page 5 of 7
Communications, 435 U.S. 589, 598 (1978) (“[C]ourts have refused to permit their files to
serve as reservoirs of libelous statements for press consumption . . . .”); Amodeo…
giuffre-maxwell
gov.uscourts.nysd.447706.1118.0
21 pg
…Id. at 49 n.22; Martindell, 594 F.2d at 296–97 (“In the present case the deponents
testified in reliance upon the Rule 26(c) protective order, absent which they may have refused to
testify. . . . (T)he witnesses were…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.9
21 pg
…Civ. P. 26(f) (3) (C). Defendant having
admitted to deletion practices that indicate relevant documents
and also refused to detail document search methods, good cause
exists to warrant court supervised examination of her electronic
devices. Accordingly, Plaintiff's motion…
giuffre-maxwell
gov.uscourts.nysd.447706.354.0
40 pg
…Plaintiff “identify … the exact false statement.” True to form, Plaintiff
identified only statements referenced in her Complaint and refused to provide any other “exact
false statement[s]” allegedly published by Ms. Maxwell.
ARGUMENT
This Motion concerns improper objections and…
giuffre-maxwell
gov.uscourts.nysd.447706.231.0
23 pg
…As to both, Ms. Maxwell provided releases for Plaintiff’s signature.
On March 16, 2016, Plaintiff refused to provide the names of any of Plaintiff’s treating
physicians, nor the requested releases, claiming “privilege.” Menninger Decl., Ex. A.
On March…