giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…requiring a certificate of conferral prior to
filing any motion to compel, and this Court’s standing order regarding conferral on all discovery
issues prior to Motions practice, the sum total of Plaintiff’s stated conferral attempt is a footnote…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.5
4 pg
…
13 A. If Mr. Rizzo was standing right
14 here in front of me, I wouldn't know who he
15 is.
16 Q. Does that mean you are saying that
17 you never met him or simply that you…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.15_1
4 pg
…correct?
13 A. If was standing right
14 here in front of me, I wouldn't know who he
15 is.
16 Q. Does that mean you are saying that
17 you never met him or simply that you don…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.37
9 pg
…Alan Dershowitz intentionally and wrongfully submitted a misleading affidavit to this
Court, knowing that Non-Pa1ty Virginia Roberts had a standing objection to the disclosure of
confidential settlement discussions. Dershowitz filed the affidavit with the sole purpose of putting
it…
giuffre-maxwell
gov.uscourts.nysd.447706.994.0
14 pg
…J. Doe has not filed a motion to intervene in this matter, nor has he filed a motion to proceed
anonymously. He lacks standing to participate, and his filing should not be considered for that
reason alone. See Dkt. 225…
giuffre-maxwell
gov.uscourts.nysd.447706.69.2
21 pg
…mental anguish, humiliation,
embarrassment, loss of self-esteem, loss of standing in the community, loss of
dignity and invasion of privacy in her public and private life not less than
$30,000,000.00.
a. Computation Analysis
i. Under New…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…Order.
II. Does overstates the reliance interests and the extent to which they would be
frustrated by Dershowitz being granted confidential access to certain materials.
Regardless of whether Doe even has standing to argue reasonable reliance, he grossly
overstates the…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…requiring a certificate of conferral prior to
filing any motion to compel, and this Court’s standing order regarding conferral on all discovery
issues prior to Motions practice, the sum total of Plaintiff’s stated conferral attempt is a footnote…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…Giuffre. He filed his affidavit in the public court
file, despite knowing Ms. Giuffre’s standing objections. He then alerted the media (specifically
the New York Times) to these statements. After Giuffre filed an emergency motion to seal the
affidavit…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.9
12 pg
…waive the
15 confidentiality agreement.
16 MR. PAGLIUCA: And we can have -- you
17 can have a standing objection to that on
18 those grounds related to any question I ask
19 about the settlement agreement with
20 Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…He is a member
in good standing of the Utah bar and handles legal cases on a paid and pro bono basis in Utah
and elsewhere.
Dershowitz Has Made Defamatory Statements Alleging Conduct Incompatible with Proper
Exercise ofEdwards and Cassell…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.24
4 pg
…so comfortable with the sex that
was going on that he would even come and chat with Epstein while I was giving oral sex to Epstein." Dershowitz
called that allegation absurd.
"Alan Dershowitz was standing there and talking about what…
giuffre-maxwell
gov.uscourts.nysd.447706.68.0
17 pg
…may properly consider a
number of factors. In this case, the jury was instructed to consider: [1] the plaintiff's standing in
the community, [2] the nature of defendant's statements made about the plaintiff, [3] the extent to
which…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.33
24 pg
…mental anguish, humiliation,
embarrassment, loss of self-esteem, loss of standing in the community, loss of
dignity, and invasion of privacy in her public and private life not less than
$30,000,000.00”; and
(C) Estimated lost income of…
giuffre-maxwell
gov.uscourts.nysd.447706.363.13
15 pg
…As an initial matter, Maxwell cites older decisions standing for the principle that the
reporter’s privilege “does not exist if the newsman is called on to testify what he personally
observed.” Response at 2-3. But those decisions predate…
giuffre-maxwell
gov.uscourts.nysd.447706.64.0
14 pg
…mental
anguish, humiliation, embarrassment, loss of self-esteem, loss of standing in the
community, loss of dignity, and invasion of privacy in her public and private life –precise
amount yet to be computed, but not less than $30,000,000;…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.1_2
24 pg
…mental anguish, humiliation,
embarrassment, loss of self-esteem, loss of standing in the community, loss of
dignity, and invasion of privacy in her public and private life not less than
$30,000,000.00”; and
(C) Estimated lost income of…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.30
4 pg
…so comfortable with the sex that
was going on that he would even come and chat with Epstein while I was giving oral sex to Epstein." Dershowitz
called that allegation absurd.
"Alan Dershowitz was standing there and talking about what…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.13
15 pg
…As an initial matter, Maxwell cites older decisions standing for the principle that the
reporter’s privilege “does not exist if the newsman is called on to testify what he personally
observed.” Response at 2-3. But those decisions predate…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.6
134 pg
…in the event you choose to challenge 4 Q. You understand that the case caption on the
5 the essential applicability of the 5 subpoena you received is Virginia Giuffre versus
6 long-standing Fifth Amendment privilege. 6 Ghislaine Maxwell…
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