giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…room had a closet that contained a locked gun locker . The
combination was entered by Banasiak in the presence of Sgt. Frick and
the safe was opened. Items were taken from the room. See the
completed property receipt for a…
giuffre-maxwell
gov.uscourts.nysd.447706.356.0
17 pg
…win. The girls’ mother told me by phone that she had thought her daughters would
6
Case 1:15-cv-07433-RWS Document 315 Filed 07/29/16 Page 7 of 17
be safe under Epstein’s roof, not…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
…room had a closet that contained a locked gun locker . The
combination was entered by Banasiak in the presence of Sgt. Frick and
the safe was opened. Items were taken from the room. See the
completed property receipt for a…
giuffre-maxwell
1320-13
45 pg
…room had a closet that contained a locked gun locker . The
combination was entered by Banasiak in the presence of Sgt. Frick and
the safe was opened. Items were taken from the room. See the
completed property receipt for a…
giuffre-maxwell
gov.uscourts.nysd.447706.315.0
17 pg
…win. The girls’ mother told me by phone that she had thought her daughters would
6
Case 1:15-cv-07433-LAP Document 315 Filed 07/29/16 Page 7 of 17
be safe under Epstein’s roof, not…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.14
7 pg
…Q. -- through here as GM --
19 A. Yes.
20 Q. -- just by the initials, are we able to
21 safely know that that is Ghislaine Maxwell?
22 A. Yes.
23 MR. PAGLIUCA: Object to form and
24 foundation.
25 MR…
giuffre-maxwell
gov.uscourts.nysd.447706.1318.0
3 pg
…1306. Based on
counsel's representations concerning Doe 107's safety in her
current country, the Parties and the Miami Herald consent to
redacting Doe 107's name and any personally identifying
information in the docket entries that the Court…
giuffre-maxwell
gov.uscourts.nysd.447706.43.0
15 pg
…July 30, 2015)..............................................................................7
Rock Salt Co., LLC v. Norfolk S. Corp.,
228 F.R.D. 426 (W.D.N.Y. 2004) ...............................................................................................8
Safeco Ins. Co. of America v. M.E.S., Inc.,
No. 09-CV-3312, 2013 WL 1680684…
giuffre-maxwell
gov.uscourts.nysd.447706.201.0
5 pg
…to protect a party or person from annoyance, embarrassment, oppression, or
undue burden or expense.” “Federal courts may also issue protective orders to safeguard the
identity of witnesses.” Kinlaw v. Walsh, 2011 WL 4620966, at *1 (S.D.N.Y…
giuffre-maxwell
gov.uscourts.nysd.447706.1317.0
3 pg
…1306. Based on
counsel's representations concerning Doe 107's safety in her
current country, the Parties and the Miami Herald consent to
redacting Doe 107's name and any personally identifying
information in the docket entri…
giuffre-maxwell
gov.uscourts.nysd.447706.57.3
39 pg
…the incident.
It included interviews conducted, the outcome of the investigations the operator
of the site undertook as part of the safety management system it was required to
have by the COMAH Regulations, and the reports of the accident investigation
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…in its in camera
review before ordering Defendant to produce them. Yet Dershowitz waited until after discovery closed and until
after he was safe from receiving a notice of deposition in this matter, before he filed his intervention motion.
Unsurprisingly…
giuffre-maxwell
gov.uscourts.nysd.447706.1100.1
13 pg
…and not for any civil proceeding or any purpose
other than the defense of this action;
b) Shall be maintained in a safe and secure
manner;
c) Shall be reviewed and possessed by the
Defendant in hard copy solely in…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.16
10 pg
…Okay. After speaking to the police or while speaking to the police, do you remember
telling them that you're not safe because you're talking about this?
MR. PAGLIUCA: Object to form and foundation.
THE WITNESS: Yes.
BY MR…
giuffre-maxwell
gov.uscourts.nysd.447706.1100.0
16 pg
…and not for any civil proceeding or any purpose
other than the defense of this action;
b) Shall be maintained in a safe and secure
manner;
c) Shall be reviewed and possessed by the
Defendant in hard copy solely in…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.22
31 pg
…in its in camera
review before ordering Defendant to produce them. Yet Dershowitz waited until after discovery closed and until
after he was safe from receiving a notice of deposition in this matter, before he filed his intervention motion.
Unsurprisingly…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.18
8 pg
… Okay. After speaking to the police or
16 while speaking to the police, do you remember
17 telling them that you're not safe because you're
18 talking about this?
19 MR. PAGLIUCA: Object to form and
20 foundation…
giuffre-maxwell
gov.uscourts.nysd.447706.370.0
17 pg
…value of home; filing of
tax returns, savings, checking, or other bank deposits, investment deposits, ownership of a safe
deposit box, cash on hand and pending legal actions for money. Evans v. Celise, No. 92-civ-
8430 (PKL), 1994 WL…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.19
17 pg
…value of home; filing of
tax returns, savings, checking, or other bank deposits, investment deposits, ownership of a safe
deposit box, cash on hand and pending legal actions for money. Evans v. Celise, No. 92-civ-
8430 (PKL), 1994 WL…
giuffre-maxwell
gov.uscourts.nysd.447706.15.0
29 pg
…the 10th Circuit has deemed it a “safe presumption” that Colorado Supreme Court would adopt the various
provisions of the Restatement (Second) of Torts (1977) as part of “its common law of defamation” based on its
decisions and Uniform Jury…
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