giuffre-maxwell
gov.uscourts.nysd.447706.1296.16
2 pg
…922) (the “June 2017 Letter”). Last year, following the
settlement of this action, Intervenor anticipated the possibility that this Court might be faced with
an unsealing motion, or one to de-designate certain materials previously designated as
“confidential” under the…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.17
16 pg
…the Ransome deposition, notwithstanding her prior letter requesting that relief
1
Intervenor Dershowitz respectfully submits that issues concerning the confidentiality of particular materials under
the protective order are not mooted by the settlement of the underlying action. See Gambale v…
giuffre-maxwell
gov.uscourts.nysd.447706.749.0
9 pg
…16) ..................................................................................................................... 25
17. The Parties agree to preclusion of all documents and discussion of the Jane Doe 102
case, including the settlement of those claims (Motion in Limine 17) ......................... 26
…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 15 of 40
the nature of the Income, whether a loan, investment proceeds, legal settlement, asset sale,
gift, or other source.
Response to Interrogatory No. 10
Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…of the Income, whether a loan, investment proceeds, legal settlement, asset sale,
gift, or other source.
16
Case 1:15-cv-07433-LAP Document 1320-37 Filed 01/03/24 Page 18 of 48
Response to Interrogatory No. 10
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.9
12 pg
…283
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. PAGLIUCA:
5 Q. In 2009, you entered into a settlement
6 agreement with Ms. Giuffre, formerly known as
7 Ms. Roberts, the Plaintiff in this case…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…of the Income, whether a loan, investment proceeds, legal settlement, asset sale,
gift, or other source.
16
Case 1:15-cv-07433-LAP Document 1331-3 Filed 01/05/24 Page 18 of 48
Response to Interrogatory No. 10
…
giuffre-maxwell
gov.uscourts.nysd.447706.1266.0
4 pg
…that
progress. Thus, although the merits of this litigation were
resolved years ago via settlement, TGP’s intervention at this
time would unduly delay the adjudication of the rights of the
original parties with respect to the protective order, at…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…dates on which any such Income was received, and
the nature of the Income, whether a loan, investment proceeds, legal settlement, asset sale,
gift, or other source.
Response to Interrogatory No. 10
Ms. Giuffre objects to this interrogatory in that…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…the dates on which any such Income was received, and the
nature of the Income, whether a loan, investment proceeds, legal settlement, asset sale, gift, or
other source.
11. Identify any facts upon which You base Your contention that You…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…dates on which any such Income was received, and
the nature of the Income, whether a loan, investment proceeds, legal settlement, asset sale,
gift, or other source.
Response to Interrogatory No. 10
Ms. Giuffre objects to this interrogatory in that…
giuffre-maxwell
1320-37
48 pg
…of the Income, whether a loan, investment proceeds, legal settlement, asset sale,
gift, or other source.
16
Case 1:15-cv-07433-LAP Document 1320-37 Filed 01/03/24 Page 18 of 48
Response to Interrogatory No. 10
…
giuffre-maxwell
gov.uscourts.nysd.447706.71.3
40 pg
…1:15-cv-07433-RWS Document 71-3 Filed 03/23/16 Page 15 of 40
the nature of the Income, whether a loan, investment proceeds, legal settlement, asset sale,
gift, or other source.
Response to Interrogatory No. 10
Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…of the Income, whether a loan, investment proceeds, legal settlement, asset sale,
gift, or other source.
16
Case 1:15-cv-07433-LAP Document 235-3 Filed 06/21/16 Page 18 of 48
Response to Interrogatory No. 10
…
giuffre-maxwell
gov.uscourts.nysd.447706.70.0
15 pg
…search did not yield any responsive documents, and she stated
that in her responses.
o Defendant wrongfully states that Plaintiff will not produce a copy of her settlement
agreement with Epstein when in fact, Plaintiff agreed to produce the settlement…
giuffre-maxwell
gov.uscourts.nysd.447706.1024.0
7 pg
…may
prompt the parties to settle. The public still has a right to know that the filing of the
complaint in our courts influenced the settlement of the dispute: “When a complaint
is filed, and the authority of the people…