giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…264-1). Yet,
during her second deposition, Defendant again refused to answer numerous questions regarding
sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the
Court should direct her to fully answer the relevant questions…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…264-1). Yet,
during her second deposition, Defendant again refused to answer numerous questions regarding
sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the
Court should direct her to fully answer the relevant questions…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…264-1). Yet,
during her second deposition, Defendant again refused to answer numerous questions regarding
sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the
Court should direct her to fully answer the relevant questions…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.6
10 pg
…particular, Ms. Giuffre seeks to ask the Defendant questions
regarding her participation in or knowledge of sexual activities connected with Jeffrey Epstein’s
sexual abuse of females. Such questions are entirely appropriate in the discovery phase of this
case, particularly…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.10_2
10 pg
…particular, Ms. Giuffre seeks to ask the Defendant questions
regarding her participation in or knowledge of sexual activities connected with Jeffrey Epstein’s
sexual abuse of females. Such questions are entirely appropriate in the discovery phase of this
case, particularly…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION FOR
PROTECTIVE ORDER REGARDING FINANCIAL INFORMATION
Plaintiff, Virgin…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.1
17 pg
…264-1). Yet,
during her second deposition, Defendant again refused to answer numerous questions regarding
sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the
Court should direct her to fully answer the relevant questions…
giuffre-maxwell
1320-6
10 pg
…particular, Ms. Giuffre seeks to ask the Defendant questions
regarding her participation in or knowledge of sexual activities connected with Jeffrey Epstein’s
sexual abuse of females. Such questions are entirely appropriate in the discovery phase of this
case, particularly…
giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…11
VII. Doe 183’s Objection Should Be Overruled. ........................................................ 12
A. Doe 183’s Arguments Regarding Judicial Documents............................. 12
B. Doe 183’s Purported Countervailing Interests .....................…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…3771.
DE1. She alleged that Jeffrey Epstein had sexually abused her and that the United States had
entered into a secret non-prosecution agreement (NPA) regarding those crimes in violation of her
rights. At the first court hearing on the…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.46
14 pg
…her newly disclosed
employment records and thus it should be deemed admitted. Apparently, she still contests
questions regarding other items not disclosed until after her deposition, including (a) iCloud and
Hotmail emails, (b) school records from Forest Hills High School…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.1_1_1_1
10 pg
…1
Defendant has labelled her entire deposition transcript as Confidential at this time. Counsel for
the parties conferred at the deposition regarding answering questions.
Yet during her deposition, Defendant refused to answer any questions that she construed
as having…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.16
30 pg
…AND THEREFORE, NO
PREJUDICE ......................................................................................................................19
III. MS. GIUFFRE HAS FULFILLED HER REQUIREMENTS REGARDING HER
RULE 26 DISCLOSURES ...............................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.143.0
10 pg
…Confidential at this time. Counsel for
the parties conferred at the deposition regarding answering questions.
1
Case 1:15-cv-07433-LAP Document 143 Filed 05/05/16 Page 2 of 10
Yet during her deposition, Defendant refused to…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…3771.
DE1. She alleged that Jeffrey Epstein had sexually abused her and that the United States had
entered into a secret non-prosecution agreement (NPA) regarding those crimes in violation of her
rights. At the first court hearing on the…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.15
14 pg
…her newly disclosed
employment records and thus it should be deemed admitted. Apparently, she still contests
questions regarding other items not disclosed until after her deposition, including (a) iCloud and
Hotmail emails, (b) school records from Forest Hills High School…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…a). Nor has he met Rule 24(b)’s standards for discretionary intervention for four reasons:
First, Dershowitz has another forum in which to litigate and defend his reputational interests – a
pending defamation action regarding this very case; second, Dershowitz…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.7
30 pg
…AND THEREFORE, NO
PREJUDICE ......................................................................................................................19
III. MS. GIUFFRE HAS FULFILLED HER REQUIREMENTS REGARDING HER
RULE 26 DISCLOSURES ...............................................................................…
giuffre-maxwell
1320-9
10 pg
…3771.
DE1. She alleged that Jeffrey Epstein had sexually abused her and that the United States had
entered into a secret non-prosecution agreement (NPA) regarding those crimes in violation of her
rights. At the first court hearing on the…
giuffre-maxwell
1320-2
10 pg
…Confidential at this time. Counsel for
the parties conferred at the deposition regarding answering questions.
Case 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 2 of 10
Yet during her deposition, Defendant refused to…
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