giuffre-maxwell
gov.uscourts.nysd.447706.931.0
15 pg
… One set of
10 them are a bunch of photographs. I have looked at them,
11 nothing prurient about them, they all predate the statute of
12 limitations time period and were used during the deposition.
13 THE COURT: Yes…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.15
11 pg
…to establish
that Jane Doe 43’s claims should be barred because they are outside the ten (10) year statute of
limitation period and also that they somehow establish that Epstein is not within the New York
Court’s jurisdiction.
…
giuffre-maxwell
gov.uscourts.nysd.447706.26.1
26 pg
…in order for
of allegedly defamatory statement gave rise to defamation claim to survive motion to dismiss,
new defamation claim against purported allegedly defamatory statement must contain at
defamer, and thus statute of limitations did not least one false factual…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…him again.”
Instead, Boies said that Dershowitz has reverted to a “very sad” PR campaign against the lawyers
representing Roberts.
Dershowitz disputed Boies’s comments that he declined to waive the statute of limitations, saying that he
filed an affidavit…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.6
134 pg
…22 question, we can use the invocation that we 22 taken on the absence of the meaningful
23 just did in response to your second 23 Statute of Limitations, in terms of our
24 question, or we simply can say…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…precepts of fairness.
More practically, nothing precludes participants in this matter from publicly disclosing
their own allegations with more particularity. This is true in two key respects. First, New
York’s recent legislation extending and revising the statute of limitations…
giuffre-maxwell
gov.uscourts.nysd.447706.1338.1
134 pg
…22 question, we can use the invocation that we 22 taken on the absence of the meaningful
23 just did in response to your second 23 Statute of Limitations, in terms of our
24 question, or we simply can say…
giuffre-maxwell
gov.uscourts.nysd.447706.1118.0
21 pg
…interests. Finally, like Mr.
Dershowitz’s original Motion, the Government here seeks all deposition material and exhibits,
sealed or unsealed, without any limitations on the scope of the needs of their case against Mr.
Epstein’s estate. (Doc. # 1113, p…
giuffre-maxwell
gov.uscourts.nysd.447706.70.0
15 pg
…in clear
violation of Local Rule 33.3, and Ms. Giuffre was under no obligation to respond. While
Defendant has elected to ignore the limitations in Rule 33.3, Ms. Giuffre has complied with the
terms of the rule and…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…dissemination of confidential information or
information which will properly annoy, embarrass, or oppress any
party, witness, or person providing discovery in this case." ECF
Dkt. 62. The Protective Order applied broadly "to all documents,
materials, and information, including without limitation…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…§ 8 ...........................................................................................................1, 2, 3, 6
Statutes
N.Y. Civ. Rights Law § 79-h ................................................................................................. passim
…
giuffre-maxwell
gov.uscourts.nysd.447706.551.0
17 pg
…motion, the court may permit anyone to intervene who
is given a conditional right to intervene by a federal statute or has a claim or defense that shares
with the main action a common question of law or fact.” Fed…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…is codified under Florida's Title VII Evidence. The
statute provides that neither an attorney nor a client may be compelled to divulge confidential
communications between a lawyer and client which were made during the rendition of legal
services. Fla…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.20
21 pg
…The conduct expl i citly described by statute as
privileged does not operate as waiver, and again Defendant has
provided no factual basis to suggest Plaintiff has
misrepresented the identity or role of the third-parties listed .
Defendant ' s request…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…Sys., Inc.,
752 F.2d 16 (2d Cir. 1984) .................................................................................................. 10, 11
4
Case 1:15-cv-07433-LAP Document 1259 Filed 07/28/22 Page 5 of 17
STATUTES
18 U.S.C. § 2 .…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.10
64 pg
…19 In fact, Globe Newspaper was the Supreme Court case
20 that specifically held that a Massachusetts statute that
21 automatically sealed material relating to sexual assault of
22 minors does not pass muster. We have to look at an…
giuffre-maxwell
gov.uscourts.nysd.447706.702.0
63 pg
…19 In fact, Globe Newspaper was the Supreme Court case
20 that specifically held that a Massachusetts statute that
21 automatically sealed material relating to sexual assault of
22 minors does not pass muster. We have to look at an…
giuffre-maxwell
gov.uscourts.nysd.447706.96.0
15 pg
…City of New York
10 CIV. 4228 (RWS), 2015 WL 4610422 (S.D.N.Y. July 23, 2015) ....................................9, 10
Statutes
Federal Rule of Civil Procedure 26 .................................................................................................8
Other
In re: Pilot Project Regarding …
giuffre-maxwell
gov.uscourts.nysd.447706.1199.4_1
4 pg
…protect the identity of Ms.
Giuffre's minor children, and to protect Ms. Giuffre's privacy interests which are naturally
implicated in the potential release of domestic violence records. Colorado statutes recognize and
protect the privacy of domestic violence victims…
giuffre-maxwell
gov.uscourts.nysd.447706.370.0
17 pg
…in many actions (including
actions for double and treble damages authorized by various statutes), it is readily
seen that a rule permitting unlimited examination before trial of a defendant as to
his wealth in a punitive damage action could have…