giuffre-maxwell
gov.uscourts.nysd.447706.1218.44
4 pg
…parties who are not related to the respondent Government. These unnecessary details shall be
stricken."
The two "non-parties" have been Prince Andrew and Alan Dershowitz.
http://jewishbusinessnews.com/2015/04/08/after-vindication-afan-dershowitz-vows-to-sue-s.. …
giuffre-maxwell
gov.uscourts.nysd.447706.88.0
7 pg
…of
Florida. In pleadings filed in that action, Mr. Edwards made representations on behalf of the
Plaintiff here that were stricken by the Court as “immaterial and impertinent.” These statements
were publicized and subsequently denied by Ms. Maxwell. Thereafter, Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.69.2
21 pg
…the NPA (pg. 3) and “The Government was well aware of Jane
Doe No. 3 when it was negotiating the NPA” (pg. 6) were stricken by Judge
Marra.]
13. January 21, 2015 Declaration of Jane Doe No. 3 filed in…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…2015. As discussed below,
several paragraphs in this motion were later stricken by Judge Marra.
3
This document is currently restricted/under seal in the CVRA case, although an order sealing it is not found in the
Court record so…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…The entire argument and reference to the transcript must be ignored and stricken
based on Plaintiff’s failure to produce in discovery the transcript she relies on.
6
Case 1:15-cv-07433-LAP Document 1332-1 Filed 01…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…The entire argument and reference to the transcript must be ignored and stricken
based on Plaintiff’s failure to produce in discovery the transcript she relies on.
6
Case 1:15-cv-07433-LAP Document 1330-16 Filed 01…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.4_1
29 pg
…Epstein and the Government owed them CVRA duties), especially
considering that these details involve non-parties who are not related to the respondent Government. These
unnecessary details shall be stricken.” See Menninger Decl., Ex. D.
5
Case 1:15…
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
…was in relation to. And guess what?
4 Judge Marra down in the Southern District of Florida has
5 stricken the declaration from public access. He has stricken
6 the actual paragraphs making all of these allegations, and has
7…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.0
18 pg
…as discussed
below), the Rule 21 Motion will be denied.
The Court also concludes that portions of the Rule 21 Motion—and related
filings—should be stricken from the record. Pending for this Court’s consideration is a Motion
for…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…Kenneth A. Marra,
Judge) sua sponte struck all allegations against additional parties from
the pleadings, including those against Dershowitz, and therefore
denied Dershowitz’s motion as moot.5
The stricken allegations, however, quickly found their way into
the press, and…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.18
23 pg
…was in relation to . And guess what?
4 Judge Marra down in the Southern District of Florida has
5 stricken the declaration from public access. He has stricken
6 the actual paragraphs making all of these allegations, and has
7…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.3
26 pg
…the NPA (pg. 3) and "The Government was well aware of Jane
Doe No. 3 when it was negotiating the NPA" (pg. 6) were stricken by Judge
Marra.]
13. January 21, 2015 Declaration of Jane Doe No. 3 filed in…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.14_2
40 pg
…2015. As discussed below,
several paragraphs in this motion were later stricken by Judge Ma1rn.
3
This document is cmTently restricted/under seal in the CVRA case, although an order sealing it is not found in the
Cowt record so…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…omitted). “Striking
allegations from a pleading ‘is a drastic remedy to be resorted to only when required for the
purposes of justice,’ and only when the allegations to be stricken have ‘no possible relation to the
controversy.’” Larise Atlantis, Inc…
giuffre-maxwell
1320-18
40 pg
…2015. As discussed below,
several paragraphs in this motion were later stricken by Judge Marra.
3
This document is currently restricted/under seal in the CVRA case, although an order sealing it is not found in the
Court record so…
giuffre-maxwell
gov.uscourts.nysd.447706.542.5
11 pg
…as discussed
below), the Rule 21 Motion will be denied.
The Court also concludes that portions of the Rule 21 Motion and related
filings should be stricken from the record. Pending for this Court' s consideration is a Motion
for…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.0_2
65 pg
…to Rule 37(b), (e) and (f), Fed. R. Civ. P., be stricken;
ii. Ms. Maxwell be awarded the costs of engaging the forensic examiner.
Dated: August 1, 2016.
Respectfully submitted,
/s/ Laura A. Menninger
…
giuffre-maxwell
gov.uscourts.nysd.447706.408.0
13 pg
…allegations were false.
12. On January 5, 2015, Dershowitz filed a motion to intervene to argue to have the
allegations stricken. DE 282. Dershowitz also argued that Ms. Giuffre had not provided a sworn
affidavit attesting to the truth of…
giuffre-maxwell
gov.uscourts.nysd.447706.42.0
7 pg
…412 (M.D.N.C. 1992) (“[b]road and undirected requests for all
documents which relate in any way to the complaint are regularly stricken as too
ambiguous”).
And, Plaintiff has expanded the dictionary definition of “relate” in her definition…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…Kenneth A. Marra,
Judge) sua sponte struck all allegations against additional parties from
the pleadings, including those against Dershowitz, and therefore
denied Dershowitz’s motion as moot.5
The stricken allegations, however, quickly found their way into
the press, and…