giuffre-maxwell
gov.uscourts.nysd.447706.541.0
10 pg
… The January 2015 statement accurately denied that “with [Ms. Maxwell’s]
assistance, [Epstein] converted [Plaintiff] into what is commonly referred
to as a ‘sex slave.’” ................................................................................... 59…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.28
4 pg
…including but not limited to:
Dr. John Bowen, to whom Plaintiff was referred by Dr. Sellathuri on
November 6, 2008 (GIUFFRE 5089)
Her “own psychiatrist” to whom she stated an intent to visit on October 31,
2003…
giuffre-maxwell
gov.uscourts.nysd.447706.751.10
4 pg
…Court in southern Florida in which she claims she was forced to have sex with
several men. She is referred to as Jane Doe No. 3 in the legal filings.
In the letter the woman's lawyers sent to Buckingham…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.7
18 pg
…LAP Document 1330-7 Filed 01/05/24 Page 4 of 18
Page 179
1 JOSEPH RECAREY - CONFIDENTIAL
2 (The referred-to document was marked by
3 the court reporter for Identification as
4 Deposition Exhibit 11.)
5 BY MR…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.12
7 pg
…for clarification, which requested that the Court clarify that the deposition
would be limited to non-duplicative questioning “limited to the four areas of inquiry referred to
in the Order at page 7.” Sealed Order of March 23, 2017 at…
giuffre-maxwell
gov.uscourts.nysd.447706.24.3
3 pg
…said she would not be commenting and
referred journalists to a 2011 statement in which she said the allegations against her were “abhorrent”.
Ghislaine Maxwell’s original response to the lies and defamatory claims remains the same
Ross Gow
However…
giuffre-maxwell
gov.uscourts.nysd.447706.538.0
10 pg
… The January 2015 statement accurately denied that “with [Ms. Maxwell’s]
assistance, [Epstein] converted [Plaintiff] into what is commonly referred
to as a ‘sex slave.’” ................................................................................... 59…
giuffre-maxwell
gov.uscourts.nysd.447706.57.2
30 pg
…result of joint input into the final document, the judge at
the hearing on liability referred to below found that copyright in that final version vested
jointly in Scottish Power and USP.
2. In 2000 the claimants and LGH were…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.14
7 pg
…plane?
16 MR. EDWARDS: Yeah, the exact plane.
17 (The referred-to document was marked by
18 the court reporter for Identification as
19 Deposition Exhibit 9.)
20 MR. REINHART: You mean based on the
21 serial number?
22 MR…
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.447706.1332.14
9 pg
…this Court refused to reconsider the Order, but
reiterated that the third deposition would proceed “limited to the four areas of inquiry referred to
in the Order at page 7.” Sealed Order of March 23, 2017 at 4.
Defendant’s…
giuffre-maxwell
gov.uscourts.nysd.447706.1305.0
4 pg
…mention “international comity” or any analogous phrase in
submission to the District Court). Even if Doe 171 referred to her purported legal rights in her
home country, “stating an issue without advancing an argument” is not enough to avoid forfeiture…
giuffre-maxwell
gov.uscourts.nysd.447706.1126.0
3 pg
…23, 2020 order of the District Court.
In the interest of judicial economy, any further appeal in this civil case shall be referred to
this panel.
The mandate shall issue forthwith.
FOR THE COURT:
Cather…
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.447706.1021.0
18 pg
…endeavored to do the same type of review
6 that Ms. McCawley just referred to and I think we would be in a
7 position to confer with Ms. McCawley and reach agreement on the
8 documents that we both…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.37
11 pg
…1:15-cv-07433-LAP Document 1328-37 Filed 01/05/24 Page 5 of 11
Page 49
1 (The referred-to document was marked by
2 the court reporter for Identification as
3 Sjoberg Exhibit 4.)
4 BY MS…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…in January of 2015.
ANSWER:
Ms. Maxwell objects to this Interrogatory as vague and ambiguous, specifically by not defining
what types or topics of “statements” are referred to. As drafted, this Interrogatory calls for
information clearly outside the relevancy of…
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.447706.1289.0
3 pg
…2022,
Hr’g Tr. 6:5–16. Moreover, as the Court observed, Doe 171 was referred to throughout Maxwell’s
criminal trial. Id. Material related to her was also already unsealed in Brown v. Maxwell, as part
of the summary…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.0
35 pg
…315, 320, & 335.
ECF No. 1149 (referred to as “Maxwell Br.”). Attached as Exhibit A hereto is a summary chart
of her position as to each document for ease of reference.
PRELIMINARY STATEMENT
On October 19, 2020, the Second Circuit…
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