giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…Dec. 16,
2019 (DE 1016). Such materials are referred to herein as the “Sealed Materials” or “Sealed
Items.” The Sealed Materials will be enumerated in a List of Decided Motions designated by the
Court. In accordance with Brown v. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.1
4 pg
…16,
2019 (DE 1016). Such materials are referred to herein as the “Sealed Materials” or “Sealed
Item.” The Sealed Materials will be enumerated in a List of Decided Motions designated by the
Court .1 In accordance with Brown v. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.1
7 pg
…Dec. 16,
2019 (DE 1016). Such materials are referred to herein as the “Sealed Materials” or “Sealed
Items.” The Sealed Materials will be enumerated in a List of Decided Motions designated by the
Court . In accordance with Brown v. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.2
4 pg
…Such materials are referred to herein as the “Sealed Materials” or “Sealed
Item.” The Sealed Materials are will be enumerated in the a List of Decided Motions designated
by the Court (Doc.1007-1) approved by the Court on January…
giuffre-maxwell
gov.uscourts.nysd.447706.1044.0
13 pg
…Dec. 16,
2019 (DE 1016). Such materials are referred to herein as the “Sealed Materials” or “Sealed
Items.” The Sealed Materials will be enumerated in a List of Decided Motions designated by the
Court . In accordance with Brown v. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1108.0
5 pg
…Dec. 16,
2019 (DE 1016). Such materials are referred to herein as the “Sealed Materials” or “Sealed
Items.” The Sealed Materials will be enumerated in a List of Decided Motions designated by the
Court . In accordance with Brown v. Maxwell…
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.447706.69.2
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.447706.1328.14
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.447706.1247.0
25 pg
…the non-parties to be addressed in the second round of objection briefing. DE 1243.
Although Plaintiff referred to this Doe as “Doe 169,” they are Doe 171. Plaintiff’s counsel sent
Doe 171’s counsel an email to inform…
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…
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