giuffre-maxwell
gov.uscourts.nysd.447706.57.1
26 pg
…Discovery — Privilege — Accident report by servants
of railways board in pursuance of practice of board—Partly
p prepared for safety purposes and partly for obtaining legal
^ advice in anticipation of legal proceedings—Whether latter
purpose to be dominant for…
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.447706.1201.1_1
17 pg
…university, which she desperately wanted - and
would win. The girls’ mother told me by phone that she had thought her daughters would
6
be safe under Epstein’s roof, not least because he phoned her to reassure her, and…
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.447706.1218.1
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 1218-1 Filed 07/15/21 Page 7 of 17
be safe under Epstein’s roof…
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.447706.15.0
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
…clearly asked solely for the purpose of
embarrassing, intimidating and harassing a non-party already fearful for her safety and life based
upon the abuse she suffered at the hands of Defendant and Epstein, abuse as to which she
testified…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.3
223 pg
…notice anything to my
20 law office for Virginia. She's had some safety
21 issues with respect to her location so we're not
22 going to be putting that on the record.
23 MS. BORJA: That's fine…
giuffre-maxwell
gov.uscourts.nysd.447706.1067.0
10 pg
…App’x 723, 725 (2d Cir. 2017) (noting generally that protection of ongoing
investigations and safety of witnesses may be countervailing interests).
However, Ms. Maxwell’s generalized assertion that there are ongoing criminal
investigations is wholly insufficient to warrant sealing…
giuffre-maxwell
gov.uscourts.nysd.447706.503.0
21 pg
…particular v igilance . . in
safeguarding the free press against undue inter ference ," and
"prevent(ing] undue diversion of journalistic effort and
disruption of press functions." 71 N.Y.2d at 528-29 (disc u ssing
New York Constitution, article I, …
giuffre-maxwell
gov.uscourts.nysd.447706.68.0
17 pg
…witnesses.
Regarding Ms. Giuffre’s own address, she is a child victim of sex trafficking. As a result of
personal safety concerns, Ms. Giuffre disclosed her attorney’s address and agreed to accept service
at that address. During the meet…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.40
19 pg
…Royal Palm Beach (Florida) Police Department, the
County Court in and for Palm Beach County (Florida), the Greenacres
(Florida) Department of Public Safety, and the Fremont County (Colorado)
Sheriff’s Office.
9. Employment records obtained from ET Employment Training and…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…A at 199:3-23. It is axiomatic that any conversations between Ms. Ransome and Mr.
Dershowitz in the presence of Jeffrey Epstein, a third party, are not protected by privilege.
Safeco Ins. Co. of Am. v. M.E.S.…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…to encompass
woman's decision whether or not to terminate her pregnancy, but
that this right is not absolute in that the state may properly
assert important interests in safeguarding health, in
maintaining medical standards and in protecting potential life).…
giuffre-maxwell
gov.uscourts.nysd.447706.949.0
31 pg
…My client and my reporter write
16 about those things all the time. She writes about children.
17 She writes about public officials whose information needs to be
18 redacted for safety purposes.
19 But the bottom line, your Honor…
giuffre-maxwell
gov.uscourts.nysd.447706.63.0
22 pg
…known Prime
Minister and other world leaders.” Plaintiff refused, claiming every applicable privilege, and
additionally “because naming some such individuals would jeopardize her physical safety based
on credible threats to the same (sic).” Menninger Decl. Ex. A at 12-13…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.12
223 pg
…notice anything to my
20 law office for Virginia. She's had some safety
21 issues with respect to her location so we're not
22 going to be putting that on the record.
23 MS. BORJA: That's fine…
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