giuffre-maxwell
gov.uscourts.nysd.447706.1284.0
17 pg
…BOIES SCHILLER & FLEXNER LLP
Attorneys for Plaintiff
16 BY: SIGRID S. McCAWLEY
17 HOLLAND & KNIGHT
Attorneys for Intervenors Julie Brown and Miami Herald
18 Media Company
BY: CHRISTINE N. WALZ
19
ZEIGER TIGGES & LITTLE LLP
20 Attorneys for Doe 183…
giuffre-maxwell
gov.uscourts.nysd.447706.1283.0
17 pg
…BOIES SCHILLER & FLEXNER LLP
Attorneys for Plaintiff
16 BY: SIGRID S. McCAWLEY
17 HOLLAND & KNIGHT
Attorneys for Intervenors Julie Brown and Miami Herald
18 Media Company
BY: CHRISTINE N. WALZ
19
ZEIGER TIGGES & LITTLE LLP
20 Attorneys for Doe 183…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.1
26 pg
…23 Q Can you state your full name and spell
24 your last name for the record?
25 A My name is Anthony Lewis Zach Figueroa
Southern Reporting Company (386)257-3663
Case 1:15-cv-07433-LAP Document…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
… : Case No. 15-cv-7433(RWS)
:
against :
:
GHISLAINE MAXWELL, :
:
Defendant.
…
giuffre-maxwell
gov.uscourts.nysd.447706.936.0
21 pg
… :
:
MEMORANDUM OF LAW IN SUPPORT OF PROPOSED
INTERVENORS JULIE BROWN AND MIAMI HERALD MEDIA COMPANY'S
MOTION TO INTERVENE AND UNSEAL
1
Case 1:15-cv-07433-RWS Document 936 Filed 04/06/18 Page 2 of 21
…
giuffre-maxwell
gov.uscourts.nysd.447706.1155.0_2
13 pg
…3200
Fax: 212.385.9010
Attorneys for Intervenors
Julie Brown and Miami Herald Media Company
Case 1:15-cv-07433-LAP Document 1155 Filed 11/19/20 Page 2 of 13
Intervenors Julie Brown and Miami Herald Media Co…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.6_1
14 pg
…reports which already are public and are
freely available to any private citizen, media outlet or company who lodges a simple request with
the relevant law enforcement agency. Her motives for hiding the information from the public
eye are easily…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…wherein he used his vast wealth and property holdings and a deliberately opaque web of
corporations and companies to transport young women and girls to his privately-owned islands
where they were held captive and subject to severe and extensive…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…Civ. P. 26 through 37
inclusive, or making or opposing any other motion or application, shall
quote or attach only those portions of the depositions, interrogatories,
requests for documents, requests for admissions, or other discovery or
disclosure materials, together with…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.26
27 pg
…Civ. P. 26 through 37
inclusive, or making or opposing any other motion or application, shall
quote or attach only those portions of the depositions, interrogatories,
requests for documents, requests for admissions, or other discovery or
disclosure materials, together with…
giuffre-maxwell
gov.uscourts.nysd.447706.96.0
15 pg
…2016 Correspondence. Ms. Giuffre’s attorneys have expended considerable sums of
money on the retention of an outside e-discovery management company to assist in a thorough
collection, review, and production of responsive documents to ensure compliance with her
discovery…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…to conceal these facts, other media reports suggest that
the reason that Defendant was trying to sell her townhouse “quietly” was perhaps “to put some
distance between herself and Epstein, who owns a mansion a few blocks away.”
http://pagesix…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…to conceal these facts, other media reports suggest that
the reason that Defendant was trying to sell her townhouse “quietly” was perhaps “to put some
distance between herself and Epstein, who owns a mansion a few blocks away.”
http://pagesix…
giuffre-maxwell
gov.uscourts.nysd.447706.78.0
30 pg
…Ordering [sic] that Ms. Maxwell’s deposition shall
not be held until Plaintiff has complied with the Court’s Order.”1 Defendant’s Motion to Compel
(“MTC”) at 25. Defendant’s Motion to Compel is a transparent attempt to manufacture…
giuffre-maxwell
gov.uscourts.nysd.447706.903.0
46 pg
…so Mr. Alvarez is the only
5 person who testifies, and then wins, because Lloyd is not
6 there, and Alvarez wins against the ship company. It goes up
7 on appeal, and the American Export Lines, the company, said…
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…1071], at 3.)
Under the terms of the order, discovery materials properly marked
confidential pursuant to the protective order “shall not be
disclosed or used for any purpose except the preparation and trial
of [Giuffre v. Maxwell],” (Protective Order ¶ 4…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.31
13 pg
…ignorance on how to
collect and produce documents responsive to this request without reviewing “thousands” of
presumptively privileged communications.
3
See also Southern District of New York Local Civil Rule 26.2(c); Am. Broad. Companies, Inc.
v. Aereo, Inc.…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…production. See Fla. R. Civ. P.
1.340(a) ("Each interrogatory shall be answered separately and fully in writing under oath unless
it is objected to, in which event the grounds for objection shall be stated, ... ") and Fla R. Civ…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…2044.1 (3d ed. Westlaw 2012) ............................................ 21
ALAN DERSHOWITZ, TAKING THE STAND: MY LIFE IN THE LAW (2013) ....................................... 24
"Did Dershowitz Shell Out Big Bucks to Get Settlement in Sex Case?"
by Vivia Chen, April 12, 2016......................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…and
Cassell continue to represent [Dershowitz accuser] Virginia Giuffre in separate pending
matters, and shall continue to advance her legitimate legal interests in those matters. As
expressly understood by the parties upon the execution of the Confidential Settlement
Agreement and…
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