giuffre-maxwell
gov.uscourts.nysd.447706.1256.23
4 pg
7. Attached hereto as Sealed Composite Exhibit 5 are true and correct copies of
Excerpts from the June 1, 2016 Deposition of John Alessi.
8. Attached hereto as Sealed Exhibit 6 is a true and correct copy of June 20…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.15
43 pg
…43
COMPOSITE
EXHIBIT 1
(File Under Seal)
Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 2 of 43
Case 9:16-mc-81608-DMM *SEALED* Document 4
of 6
United States District Court…
giuffre-maxwell
gov.uscourts.nysd.447706.684.0
3 pg
…Motion in Limine
to Admit the “Black Book” as Evidence in Trial.
3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of
4. Attached hereto as Sealed Composite Exhibit 2 are true and correct copies of
…
giuffre-maxwell
gov.uscourts.nysd.447706.813.0
3 pg
…hereby files this proposed redactions of the Order Denying
Defendant’s Motion for Summary Judgment. See Plaintiff’s proposed redactions attached hereto
as Sealed Exhibit 1.
Dated: March 29, 2017
Respectfully Submitted,
By: /s Sigrid McCawley
…
giuffre-maxwell
gov.uscourts.nysd.447706.733.0
3 pg
…to
Defendant’s Motion in Limine to Exclude Victim Notification Letter.
3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of
4. Attached here to as Sealed Exhibit 2 is a true and correct copy of
…
giuffre-maxwell
gov.uscourts.nysd.447706.739.0
3 pg
…in Limine to Permit Questioning Regarding Plaintiff’s Sexual History and
Reputation.
3. Attached hereto as Sealed Composite Exhibit 1 are true and correct copies of
.
4. Attached hereto as Sealed Exhibit 2 is a…
giuffre-maxwell
gov.uscourts.nysd.447706.933.0
3 pg
…8, 2017 transcript of proceedings pursuant to this Court’s Protective Order. See
Plaintiff’s proposed redactions attached hereto as Sealed Exhibit 1.
Dated: November 28, 2017
Respectfully Submitted,
By: /s Sigrid McCawley
…
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.447706.1328.29
4 pg
…for Protective Order and to Direct The Defendant To Disclose All Individuals to
Whom Defendant has Dissiminated Confidential Information (DE 335).
3. Attached hereto as Sealed Composite Exhibit 1 are true and correct copies of
Excerpts from June 24, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.2_1
3 pg
…Court to Direct Defendant To Disclose All Individuals To
Whom Defendant Has Disseminated Confidential Information.
3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of May 18, 2016,
Correspondence from Jeff Pagliuca to Meredith Schultz.
4…
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.447706.1034.0
16 pg
…PRESKA, Senior United States District Judge:
The Court has considered the parties’ various submissions
regarding the review protocol (“the Protocol”) to be utilized by
the Court in its individualized review of the sealed materials at
issue in this litigation. (See…
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.447706.1331.1
3 pg
…In Support of
Motion to Reopen Defendant’s Deposition Based on Late Production of New, Key Documents.
3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of Excerpts from
May 18, 2016, Deposition of Johanna Sjoberg.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1278.0
4 pg
…recently retained undersigned counsel in the United States to file
a narrow appeal in opposition to the release of certain sealed materials containing
information that has not previously been disclosed and is likely to cause her to suffer
irreparable harm…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.12_1
4 pg
…as Exhibit 1 is a true and correct copy of July 29, 2016,
Correspondence from Ty Gee.
4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of Excerpt from
April 22, 2016, Deposition of Ghislaine Maxwell.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.14
4 pg
…s Response in
Opposition to Defendant’s Motion in Limine to Exclude in Toto Certain Deposition Designated
by Plaintiff for Use at Trial.
3.
-
Attached hereto as Sealed Exhibit 1 is a true and correct copy of February 9,
2017…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.12
4 pg
…Declaration in Support of Plaintiff’s Motion to Compel
Data from Defendant’s Undisclosed Email Account and for Adverse Inference Instruction.
3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of Excerpts from
June 1, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.651.0
3 pg
…Testimony from Jeffrey Epstein for Purpose of Obtaining an Adverse Inference Instruction.
3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of
4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of
…
giuffre-maxwell
gov.uscourts.nysd.447706.573.0
4 pg
…in Limine to Exclude Expert Testimony and Opinion of
Professor Terry Coonan.
3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of
.
4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of
…