giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…and JANE DOE #2
v.
UNITED STATES
__________________________/
JANE DOE #3 AND JANE DOE #4’S MOTION PURSUANT TO RULE 21 FOR
JOINDER IN ACTION
COME NOW Jane Doe #3 and Jane Doe #4 (also referred to as “the new victims”)…
giuffre-maxwell
gov.uscourts.nysd.447706.1323.0
2 pg
…15-cv-7433-LAP
Dear Judge Preska:
Intervenor Alan Dershowitz (hereinafter referred to as “Dershowitz”) joins in the letter
motion filed by Intervenors Julie Brown and Miami Herald Media Company (hereinafter
collectively referred to as “Herald”) requesting that the Court…
giuffre-maxwell
1320-9
10 pg
…and JANE DOE #2
v.
UNITED STATES
__________________________/
JANE DOE #3 AND JANE DOE #4’S MOTION PURSUANT TO RULE 21 FOR
JOINDER IN ACTION
COME NOW Jane Doe #3 and Jane Doe #4 (also referred to as “the new victims”)…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.3
10 pg
…and JANE DOE #2
v.
UNITED STATES
__________________________/
JANE DOE #3 AND JANE DOE #4’S MOTION PURSUANT TO RULE 21 FOR
JOINDER IN ACTION
COME NOW Jane Doe #3 and Jane Doe #4 (also referred to as “the new victims”)…
giuffre-maxwell
gov.uscourts.nysd.447706.69.2
21 pg
…Palm
Beach home, attached hereto as Exhibit 7.
8. Jeffrey Epstein’s Phone Book, also referred to as his “Black Book,” attached hereto
as Exhibit 8.
9. Deposition of Sarah Kellen, attached hereto as Composite Exhibit 9.
10. Deposition Transcripts…
giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…judicial documents “may mean.” Doc.993 at 6. That is just willful
ignorance. Plaintiff’s counsel was present at the September 4 hearing when the Court three times
referred to “negligibly judicial” documents. See 9/4/19 Tr. at 10…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…did insert Mr. Dershowitz’s name in her book manuscript
but she did not allege therein that she had any sexual relations with him, rather she simply
referred to him as a business acquaintance of Mr. Epstein’s. It was…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…what Ms. Giuffre’s own counsel have referred to as
the “strong current media interest in the case”—which Ms. Giuffre has worked to sustain,
including by selling her story—bolsters the public’s right to access the Requested Documents…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…McCAWLEY: We have a copy of what was taken.
21 When it's referred to as "the black book," I believe
22 that's because that's sort of colloquially what they referred
23 to -- the house staff referred to…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.6
10 pg
…who shall be paid for
by Epstein. Epstein's counsel may contact the identified individuals
through that representative.
8. If any of the individuals referred to in.paragraph (7), supra, cl.equ te>
tile suit pursuant to 18 U.S…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.3
223 pg
…remember off the top of my head,
6 I'm sorry.
7 Q. You also referred to prominent American
8 politicians. What prominent American politicians other
9 than the ones we've already named were you sexually
10 trafficked to…
giuffre-maxwell
gov.uscourts.nysd.447706.89.0
10 pg
…Giuffre in this matter. In addition, Judge Marra has recently referred the parties to
mediation at the end of May. If the mediation is successful, the case will be resolved.
Defendant appears to be taking the position that Professor Cassell…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…social worker, or other medical or mental health
care practitioner, and includes any Person or entity referred to as a “Health Care Professional” or
“Health Care Institution” in Colorado Revised Statute § 13-64-202(3) and (4).
9. “Identify” means…
giuffre-maxwell
gov.uscourts.nysd.447706.364.0
32 pg
…what Ms. Giuffre’s own counsel have referred to as
the “strong current media interest in the case”—which Ms. Giuffre has worked to sustain,
including by selling her story—bolsters the public’s right to access the Requested Documents…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.3
26 pg
…Palm
Beach home, attached hereto as Exhibit 7.
8. Jeffrey Epstein's Phone Book, also referred to as his "Black Book," attached hereto
as Exhibit 8.
9. Deposition of Sarah Kellen, attached hereto as Composite Exhibit 9.
10. Deposition Transcripts…
giuffre-maxwell
gov.uscourts.nysd.447706.63.0
22 pg
…claims Ms. Maxwell sexually trafficked her. Interrogatory No.
8 asked her to specify the individuals referred to generally in her Florida CVRA pleading that
were the supposed participants of the alleged sexual trafficking, “including numerous prominent
American politicians, powerful business…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.4
40 pg
…in the discussion of Objection 1.
Plaintiff’s deficient answer. “Without waiving [her] objections,” Plaintiff answered ■
she
“has already produced her responsive documents” and referred the defense to 7,566 pages of
undifferentiated d…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…Ferrer, the woman identified in current court pleadings as Jane No. 3 is referred to as
“Jane Doe No. 4.” For consistency with the court pleadings, the designations in correspondence have
been modified here – as indicated by brackets – to track…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.12
223 pg
…remember off the top of my head,
6 I'm sorry.
7 Q. You also referred to prominent American
8 politicians. What prominent American politicians other
9 than the ones we've already named were you sexually
10 trafficked to…
giuffre-maxwell
gov.uscourts.nysd.447706.20.0
26 pg
…her false statements at Giuffre’s true public
description of factual events, and many persons who read Defendant’s statements reasonably
understood that those statements referred directly to Ms. Giuffre’s account of her life as a young
teenager with…
Comments