giuffre-maxwell
gov.uscourts.nysd.447706.1046.0
3 pg
…multiple times to propose five motions pertaining to J. Doe 1 and J. Doe 2, as
identified on the sealed Non-Party List, with which the Court may begin administering the Order
and Protocol for Unsealing Decided Motions, Dkt. 1044…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…On June 20, 2016, this Court
Ordered Defendant to sit for a second deposition because her refusal to answer questions posed
in her first Deposition (June 20, 2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…On June 20, 2016, this Court
Ordered Defendant to sit for a second deposition because her refusal to answer questions posed
in her first Deposition (June 20, 2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…On June 20, 2016, this Court
Ordered Defendant to sit for a second deposition because her refusal to answer questions posed
-
in her first Deposition (June 20, 2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.1
17 pg
…On June 20, 2016, this Court
Ordered Defendant to sit for a second deposition because her refusal to answer questions posed
in her first Deposition (June 20, 2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.12
10 pg
…3560022
~1gn Mc aw1ey, t,sq.
s111ccawlevPbstllp.com
January 30, 2017
…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…the July 3,
2019 Opinion of the United States Court of Appeals for the Second Circuit directed this Court to
perform a “particularized review” of materials previously filed under seal in this matter (the
“Sealed Materials”) to determine whether they…
giuffre-maxwell
gov.uscourts.nysd.447706.1285.0
6 pg
…unsealing order to remain consistent with its treatment of other Non-Party
Does who continue to experience trauma as a result of the events that are the subject
of this litigation by “keeping [her] name sealed in excerpts that discuss …
giuffre-maxwell
gov.uscourts.nysd.447706.1335.3
223 pg
…marked confidential, sealed,
22 and retained by the Special Master.
23
24
25
CONFIDENTIAL
Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 5 of 223
4
1 Dep…
giuffre-maxwell
gov.uscourts.nysd.447706.1286.0
6 pg
…unsealing order to remain consistent with its treatment of other Non-Party
Does who continue to experience trauma as a result of the events that are the subject
of this litigation by “keeping [her] name sealed in excerpts that discuss …
giuffre-maxwell
gov.uscourts.nysd.447706.1218.12
223 pg
…187
21
REPORTER'S NOTE: Exhibit 5 marked confidential, sealed,
22 and retained by the Special Master.
23
24
25
CONFIDENTIAL
4
1 Deposition taken before Deborah A. Harris,
2 …
giuffre-maxwell
gov.uscourts.nysd.447706.363.0
18 pg
…have erred on the side of strict confidentiality to avoid any semblance of violating the
Court’s Protective Order, I of course do not believe that these materials should remain sealed
permanently. In the event the Court grants my application…
giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…public access to judicial documents in a case of great
public interest like this one.1 This is especially so when many of the facts underlying this case,
and much of the information that non-parties seek to keep sealed…
giuffre-maxwell
gov.uscourts.nysd.447706.1021.0
18 pg
…That's a different issue.
14 There is a third category that I think I might propose
15 to your Honor. We were the only party to submit a request to
16 keep documents sealed and we, in our chart…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.17
12 pg
…out of any response Defendant provides within the
parameters of the Court’s June 20, 2016 Sealed Order.
As recounted more fully in the moving brief, the questions Defendant refused to answer
fall squarely within this Court’s earlier order…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…GIUFFRE001410; GIUFFRE001411; GIUFFRE00; etc.); See McCawley Dec. at Sealed
Composite Exhibit 4 Figueroa Dep. Tr. at page 200:5-12 (Defendant called him to bring girls and
he brought 16 and 17 year olds).
11
See, e.g., McCawley Dec…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…These files demonstrate the magnitude of Epstein's criminal
conduct and the unlikelihood that Dershowitz was ignorant of his confidant and close friend's
criminal behavior.
Dershowitz complains that some of the documents are sealed or otherwise unavailable to
him…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.4
21 pg
…to support a colorable
argument (or on the basis of misrepresented or false facts or law) will be met with
sanctions.
June 20, 2016, Sealed Order at 13-14. The Defendant ignored this Order, and her motion should
-
be denied.
…
giuffre-maxwell
gov.uscourts.nysd.447706.851.0
158 pg
…wasn't on the island.
7 And so in your Honor's order in 264-1, which is one of
8 the sealed orders, you did not allow us to depose him because
9 you said it was irrelevant.
10 …
giuffre-maxwell
gov.uscourts.nysd.447706.1328.7
12 pg
…Decl. at Exhibit 2, June 20, 2016 Sealed Order at p. 10 (Emphasis added).
As articulated in the moving brief, Defendant refused to answer four categories of
questions that were directly within the ambit of this Court’s Order.
First…
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